EYUS final and proposed regulations on hybrid mismatches, DCLs and conduit financing provide more certainty but some surprises
|Tax Alerts, National/Federal Taxation, L ...|United States
In final regulations (TD 9896), the United States (US) Internal Revenue Service (IRS) and the Treasury Department implement hybrid mismatch rules under Internal Revenue Code1 Sections 267A and 245A(e) and rules for dual consolidated losses (DCLs) and entity classifications (the “Final Regulations”). Sections 267A and 245A(e) were enacted under the Tax Cuts and Jobs Act (TCJA) and are aim…
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