Nathan Boidman, Michael N. Kandev, "Expected Adverse Effects of Proposed U.S. Anti-Hybrid Regulations on Inbound Financing by Canadian MNEs", Tax Notes International, February 11, 2019, p. 623

Summary Under
Tax Topics - Income Tax Act - Section 113 - Subsection 113(1) - Paragraph 113(1)(a)

Anti-hybrid rule in IRC s. 267A (p. 624)

[S]ection 267A targets deduction/non-inclusion (D/NI) situations.

A broadly worded grant of regulatory...

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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(ii) - Clause 95(2)(a)(ii)(B) - Subclause 95(2)(a)(ii)(B)(II)

Anti-hybrid rule in IRC s. 267A (p. 624)

The anti-hybrid rule in section 267A(a) simply states that the law will not allow a deduction for any...

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