Treasury and the IRS on April 7, 2020 published regulations that finalize 2018 proposed regulations addressing anti-hybrid rules under Sections 245A(e), 267A, and 1503(d). On the same date, Treasury and the IRS issued additional proposed regulations under Sections 245A(e), 881 (with respect to the anti-conduit regulations), and 951A.
PwC is in the process of reviewing the final regulations in detail; some of the key highlights we have identified thus far are set forth below. An in-depth Insight on the final regulations will be published in the coming days. In addition, we will discuss the anti-hybrid guidance on a PwC webcast scheduled for April 17 at 2:00 pm ET.
