hybrid transaction
Defined in 1 place of the United States Code.
For purposes of this section, the term "hybrid transaction" means any transaction, series of transactions, agreement, or instrument one or more payments with respect to which are treated as interest or royalties for purposes of this chapter and which are not so treated for purposes the tax law of the foreign country of which the recipient of such payment is resident for tax purposes or is subject to tax.
Source
- 2017–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