Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)
By EsqSocial Corporation 28/01/19
On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and 1503(d) of the Internal...
By: Proskauer - Tax Talks