U.S. Final Regulations Regarding Certain Hybrid Arrangements and Proposed Regulations on Hybrid Arrangements and GILTI
The U.S. IRS and Treasury have issued final regulations regarding certain hybrid arrangements and proposed regulations providing guidance involving hybrid arrangements and the allocation of deductions attributable to certain disqualified payments under Section 951a (GILTI), which were published in the Federal Register on 8 April 2020. The final and proposed regulations are summarized as follows…
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