13 November 2018

Hybrid regulations sent to OMB for review

Regulations addressing certain related-party amounts paid or accrued in hybrid transactions or with hybrid entities under the Tax Cuts and Jobs Act (TCJA) were sent to the Office of Management and Budget (OMB) for review today (November 13, 2018), the latest in a spate of regulatory projects that may be set for release soon.

Proposed regulations on foreign tax credits and regulations on the base-erosion and anti-abuse tax (BEAT) under Section 59A were sent to OMB for review last week. Rules regarding the limitation on the deductibility of business interest under Section 163(j) were listed as under review by OMB on October 25.

Regulations under review by OMB are listed here.

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Contact Information
For additional information concerning this Alert, please contact:
 
Washington Council Ernst & Young
   • Any member of the group, at (202) 293-7474.

Document ID: 2018-2269