close
Share with your friends

Initial impressions, proposed regulations implementing “anti-hybrid” provisions of new tax law

Initial impressions implementing“anti-hybrid provisions

The U.S. Treasury Department and IRS on December 20, 2018, released for publication in the Federal Register proposed regulations implementing the “anti-hybrid” provisions that were enacted as part of the new U.S. tax law (Pub. L. No. 115-97) (also referred to as the “Tax Cuts and Jobs Act” (TCJA)). The proposed regulations include new rules issued under sections 245A(e) and 267A, as well as modifications to the regulations implementing the section 1503(d) dual consolidated loss (DCL) rules.

1000

Related content

Read the proposed regulations [PDF 380 KB] (40 pages)

For the full text, read TaxNewsFlash

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us

 

Want to do business with KPMG?

 

loading image Request for proposal