A notice from the U.S. IRS has been published in the Federal Register to announce that a public hearing will be held on 25 March 2019 on proposed regulations (REG-104259-18) to provide guidance regarding the tax on base erosion payments of taxpayers with substantial gross receipts and reporting requirements thereunder. A notice has also been published to announce that a public hearing will be held on 20 March 2019 on proposed regulations (REG–104352-18) to implement sections 245A(e) and 267A of the Internal Revenue Code (Code) regarding hybrid dividends and certain amounts paid or accrued in hybrid transactions or with hybrid...