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. Rules Regarding Certain Hybrid Arrangements This document contains final regulations providing guidance regarding hybrid dividends and certain amounts paid or accrued pursuant to hybrid arrangements, which generally involve arrangements whereby U.S. and foreign tax law classify a transaction or entity differently for tax purposes. This...