hybrid dividend
Defined in 1 place of the United States Code.
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.
Source
- 2026–present26 U.S.C. § 245AInternal Revenue Code · Deduction for foreign source-portion of dividends received by domestic corporations from specified 10-percent owned foreign corporations · for purposes of this section
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.
Any amount which is treated as a dividend under section 1291(d)(2)(B) shall not be treated as a dividend for purposes of this section.
The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the provisions of this section, including regulations for the treatment of United States shareholders owning stock of a specified 10 percent 1 owned foreign corporation through a partnership.
Source
- 2017–202626 U.S.C. § 245AInternal Revenue Code · Deduction for foreign source-portion of dividends received by domestic corporations from specified 10-percent owned foreign corporations · for purposes of this section