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ON DEMAND: International Tax Series: Final and Proposed Regulations Addressing Hybrid Dividends, Hybrid Arrangements and Other Issues
Credit: 0 Credit Hours
Run Time: 84 Minutes
This panel will cover recent guidance addressing the hybrid-related international tax provisions enacted in the Tax Cuts and Jobs Act. Specifically, the panel will discuss the final regulations, released April 7, 2020, regarding hybrid dividends (section 245A(e)), certain amounts paid or accrued pursuant to hybrid arrangements (section 267A), and dual consolidated losses. The panel will also discuss proposed regulations, released April 7, addressing hybrid deduction accounts, equity interests treated as financing transactions under Treas. Reg. § 1.881-3, and certain payments between related controlled foreign corporations during a disqualified period under section 951A.
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- Lori Hellkamp, Jones Day
- John Merrick, Internal Revenue Service IRS Office of Chief Counsel (International)
- Jason Yen, U.S. Department of the Treasury
- John D. Bates, Principal, Deloitte Tax LLP (Moderator)
Please select Individual Registration to register.
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