December 18, 2018
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):
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.