Page 208 - International Taxation IRS Training Guides

Hybrids Arrangements (Cont’d)

the deduction for
 Hybrid arrangement rules disallow

or royalty payment to a related party under
an interest
a hybrid arrangement that
gives rise to an amount that

is not taxed in the recipient jurisdiction (either no

income inclusion or
a deduction)

including any payment to the extent included in
• Not
income under
subpart F

 Effective for
tax years beginning after Dec. 31, 2017

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