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...

Stay ahead of the curve

In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.

  • Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
  • Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
  • Create custom alerts for specific article and case topics and so much more!


Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Ask a question!