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TREAS/IRS | RIN: 1545-BO53 | Publication ID: Fall 2019 |
Title: Hybrid Dividends and Payments | |
Abstract:
Regulations addressing certain related party amounts paid or accrued in hybrid transactions or with hybrid entities. These regulations implement sections 245A(e) and 267A of the Internal Revenue Code (added by the TCJA) regarding hybrid dividends (i.e., dividends treated as deductible payments for foreign tax purposes) and certain amounts paid or accrued in hybrid transactions or with hybrid entities. |
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Agency: Department of the Treasury(TREAS) | Priority: Economically Significant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Final Rule Stage |
Major: Yes | Unfunded Mandates: No |
EO 13771 Designation: Other | |
CFR Citation: 26 CFR 1 | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 267A(e) |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-104352-18 Drafting attorney: Tracy M. Villecco (202) 317-6933 Reviewing attorney: Shane M. McCarrick (202) 317-6937 Treasury attorney: Jason Yen (202) 622-1776 CC:INTL | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Tracy M. Villecco Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-4965 Email: tracy.m.villecco@irscounsel.treas.gov |