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Proposed regulations under “anti-hybrid” provisions; hearing cancelled

Proposed regulations under “anti-hybrid” provisions

The U.S. Treasury Department and IRS today released for publication in the Federal Register a notice announcing that a public hearing scheduled for March 20, 2019, relating to the proposed regulations under the “anti-hybrid” provisions has been cancelled.


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Read the hearing cancellation notice [PDF 247 KB]


Proposed regulations for implementing the “anti-hybrid” provisions—enacted as part of the U.S. tax law (Pub. L. No. 115-97) (also referred to as the “Tax Cuts and Jobs Act”)—were released in December 2018. 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. Read a KPMG report of initial impressions about these proposed regulations implementing the anti-hybrid provisions: TaxNewsFlash

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