Nuts And Bolts Of The IRS' Proposed Anti-Hybrid Regulations

By Thomas Humphreys, Michael Lebovitz, Warren Payne and Brennan Young
January 17, 2019, 5:48 PM EST

The Tax Cuts and Jobs Act of 2017[1] added new Sections 245A(e) and 267A to the Internal Revenue Code of 1986.[2] Section 245A(e) denies the Section 245A dividends-received deduction for "hybrid"...

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