OIRA Receives Section 267A Regulations for Review

The IRS on November 13th submitted its proposed section 267A anti-hybrid regulations to the Office of Information and Regulatory Affairs for expedited review. Section 267A of the Tax Cuts and Jobs Act, eliminates deductions for any “disqualified related party amount” paid or accrued through a related hybrid entity or transaction. The regulations are expected to address such issues as conduit arrangements, multiple tax residences, structured transactions, and payments subject to a preferential tax regime or participation exemption system.

Read more: Proposed Regulations on Hybrid Mismatches Under OIRA Review

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