US Must Align Hybrid Rules With Global Agenda: IRS Official

Law360, Washington (January 30, 2019, 9:00 PM EST) -- In passing the 2017 U.S. tax overhaul, Congress departed from a set of global proposals for tackling hybrid transactions, but regulations under the federal statute must now be aligned with that international approach, a senior IRS official has said.

While anti-hybrid rules proposed by the Organization for Economic Cooperation and Development aren’t binding and those emerging from the revamped U.S. tax code are, a failure to “harmonize” the two sets could lead to confusion in legal disputes, according to John Merrick, senior-level counsel in the Internal Revenue Service’s Office of Associate Chief Counsel, International.

Merrick, speaking Tuesday at the District of...

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