The U.S. IRS and Treasury have issued corrections to proposed rulemaking (guidance) involving hybrid arrangements and the allocation of deductions attributable to certain disqualified payments under Section 951A (Global Intangible Low-Taxed Income).
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SUMMARY:
This document contains a correction to a notice of proposed rulemaking that was published in the Federal Register on April 8, 2020. The proposed regulations that adjust hybrid deduction accounts to take into account earnings an…