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Legal Update

IRS Releases Proposed Anti-Hybrid Regulations

2 January 2019
Mayer Brown Legal Update
The US Tax Cuts and Jobs Act of 2017 added new sections 245A(e) and 267A to the Code. 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 December 20, 2018, the Internal Revenue Service issued proposed regulations under both of these Code provisions. This Legal Update provides an overview of the proposed regulations.


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