Share with your friends

KPMG report: Initial impressions of final regulations implementing “anti-hybrid” provisions

KPMG report: Initial impressions of final regulations

Final regulations were published on April 8, 2020, in the Federal Register as guidance under sections 245A(e), 267A, and the section 1503(d) dual consolidated loss (DCL) rules.


Related content

Read the final regulations [PDF 501 KB] (56 pages as published in the Federal Register).

The final regulations (T.D. 9896) broadly adopt, with certain revisions and clarifications, the December 2018 version of proposed regulations under such sections. 

Read an April 2020 report [PDF 419 KB] prepared by KPMG LLP that provides early impressions and observations about the final regulations. Further analysis of these regulations will also be forthcoming.

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