hybrid dividend
Defined in 1 dictionary — U.S. Code
United States Code
26 U.S.C. § 245A — for purposes of this section (2 versions over time)
The term “hybrid dividend” means an amount received from a controlled foreign corporation—
(A) for which a deduction would be allowed under subsection (a) but for this subsection, and
(B) for which the controlled foreign corporation received a deduction (or other tax benefit) with respect to any income, war profits, or excess profits taxes imposed by any foreign country or possession of the United States.