Page 315 - International Taxation IRS Training Guides
P. 315
Glossary of Terms (Cont’d)
Acronym/Terms Definition
Holdco Holding Company
Hubco Foreign holding company organized in a low-tax jurisdiction, often
vested with centralized functions and centralized control of IP
Hybrid Hybrid: Flow through for US tax/Corporation for country of incorporation
HP Hybrid Partnership
IBC International Business Company
IP Intangible Property
IDR Information Document Request
LLC Limited Liability
Company
MNE Multinational Entity
PRI Permanently Reinvested Income (Foreign)
QBU Qualified Business Unit
RH Reverse Hybrid: Corporation for US tax and flow through for foreign
country of incorporation
62
