hybrid entity
Defined in 1 dictionary — U.S. Code
United States Code
26 U.S.C. § 267A — for purposes of this section (2 versions over time)
For purposes of this section, the term “hybrid entity” means any entity which is either—
(1) treated as fiscally transparent for purposes of this chapter but not so treated for purposes of the tax law of the foreign country of which the entity is resident for tax purposes or is subject to tax, or
(2) treated as fiscally transparent for purposes of such tax law but not so treated for purposes of this chapter.