Tax Reform Series 49 – Related Party Payments Involving Hybrid Entities or Hybrid Transactions


Plain Language of Change:

  • The Act includes anti-hybrid rules denying deductions for any disqualified related-party amount paid or accrued pursuant to a hybrid transaction or by, or to, a hybrid entity, for example, interest and royalties paid to related foreign persons, where the payments either are not includible or are deductible in the hands of the recipient in its residence country

  • Denies a dividends received deduction for hybrid dividends received from a CFC and treats hybrid dividends as subpart F income if received by a CFC

  • Expands the provisions of the hybrid disallowance rules to branches (domestic or foreign) and domestic entities, even if such branches or entities do not meet the statutory definition of a hybrid entity

Detailed Analysis of Related Party Payments Involving Hybrid Entities or Hybrid Transactions

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