U.S. Proposed Regulations Published on Certain Hybrid Arrangements Published
On 28 December 2018, the proposed regulations from the U.S. Treasury Department and the IRS on Rules Regarding Certain Hybrid Arrangements was published in the Federal Register. As provided in the proposed regulations, the regulations are summarized as follows:
This document contains proposed regulations implementing sections 245A(e) and 267A of the Internal Revenue Code ("Code") regarding hy…
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