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On 20 December 2018, the US Treasury released proposed regulations under the new anti-hybrid rules as enacted under Section 267A and 245A(e). Section 267A and Section 245A(e) were enacted under the 2017 tax reform act and set forth the rules for hybrid dividends and certain amounts paid or accrued in hybrid transactions or with hybrid entities.

Some of the key highlights we have identified thus far are set out below. Look for our forthcoming in-depth Insight on the Proposed Regulations.


In addition, we will discuss the new anti-hybrid rules on an upcoming Tax Reform
Readiness Series webcast.

For queries, please contact Tom Patten or speak to your usual PwC adviser.