Nuts And Bolts Of The IRS' Proposed Anti-Hybrid Regulations

Law360 (January 17, 2019, 5:48 PM EST) -- The Tax Cuts and Jobs Act of 2017[1] added new Sections 245A(e) and 267A to the Internal Revenue Code of 1986.[2] Section 245A(e) denies the Section 245A dividends-received deduction for “hybrid” dividends. Section 267A concerns payments on hybrid instruments and payments by, or to, a hybrid entity, providing that no deduction is allowed for any amount (i) paid or accrued pursuant to a “hybrid” transaction or (ii) paid by, or to, a “hybrid” entity. On Dec. 20, 2018, the Internal Revenue Service issued proposed regulations under both of these IRC provisions.[3] The proposed regulations note that if the regulations are finalized...

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