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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 is a previously recorded program, originally recorded on May 12, 2020. 
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.

Sponsored by: International Tax Committee of the D.C. Bar Taxation Community
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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)
On Demand Registration Fees **discounted pricing offered for a limited time
$10 D.C. Bar Law Student Community Member
$20 D.C. Bar Taxation Community Member
$20 Government/Nonprofit
$30 D.C. Bar Member
$50 Non-member
Please select Individual Registration to register.

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