The US IRS Publishes Regulations on Hybrid Instruments and Entities
Journal
United States
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2019 (Volume 21), No. 4
On 28 December 2018, the US Internal Revenue Service (IRS) published Proposed Regulations providing details as to the new US limitations on the deductibility of payments in respect of hybrid instruments and hybrid transactions. This article discusses the new rules extensively.