hybrid entity
Defined in 1 place of the United States Code.
For purposes of this section, the term "hybrid entity" means any entity which is either—
Source
- 2017–202626 U.S.C. § 267AInternal Revenue Code · Certain related party amounts paid or accrued in hybrid transactions or with hybrid entities · for purposes of this section
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.
Source
- 2026–present26 U.S.C. § 267AInternal Revenue Code · Certain related party amounts paid or accrued in hybrid transactions or with hybrid entities · for purposes of this section