Proposed regulations on hybrid dividends, payments provision; OIRA review completed

OMB’s Office of Information and Regulatory Affairs (OIRA) reports it has completed review of proposed regulations from the Treasury Department concerning the hybrid dividends and payments provision under the new U.S. tax law (Pub. L. No. 115-97, enacted December 22, 2017)—the law that is at times referred to as the “Tax Cuts and Jobs Act” (TCJA).

The U.S. Treasury Department and IRS would now be expected to release the proposed regulations (as described on the OIRA website):

• RIN: 1545-BO53: Hybrid dividends and payments

Regulations addressing certain related party amounts paid or accrued in hybrid transactions or with hybrid entities.

Treasury regulations that are identified as “major” regulations are subject to review by OMB’s OIRA before issuance, pursuant to Executive Order 13771.

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