Skip to main content

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.

Authors

  • Thomas A. Humphreys
    T +1 212 506 2450
  • Michael Lebovitz
    T +1 213 229 5149
  • Warren S. Payne
    Legal Professional / Consultant, Senior Advisor
    T +1 202 263 3831
  • Brennan W. Young
    T +1 212 506 2691

Related People

  • Jason S. Bazar
    T +1 212 506 2323
The Build a Report feature requires the use of cookies to function properly. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently. If you do not accept cookies, this function will not work. For more information please see our Privacy Policy

You have no pages selected. Please select pages to email then resubmit.