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.
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
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.