IRS T.D.: Hybrid Arrangement Final Regulations (IRC §245A)

Rules aimed at curbing hybrid mismatch arrangements, in which companies exploit differences between two countries’ rules to avoid taxes, the IRS stated in final regulations released April 7. The regulations also relate to dual consolidated losses and entity classifications to prevent the same deduction from being claimed under the tax laws of both the United States and a foreign jurisdiction. Additionally, the final regulations cover information reporting to facilitate the administration of certain rules in the final regulations. The regulations are effective April 8, 2020. [T.D. 9896, RIN 1545-BO53, 85 Fed. Reg. __ (Apr. 8, 2020)]

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