Page 207 - International Taxation IRS Training Guides

Hybrids Arrangements

transaction may be treated differently for
 Cross-border

and foreign tax purposes because of differences in
US
law of each country
the tax

treatment of a transaction does
 In general, the US tax

take into account foreign tax law
not

 TCJA
enacted new rules under IRC 267A to address

hybrid arrangements

 Intended to be consistent
with the approaches taken

already
in the Internal Revenue Code and tax treaties
fora
and agreed in international

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