“anti-hybrid” regulations under sections 267A, 245A(e), and 1503(d). • Sections 267A and 245A(e) were enacted in 2017 as part of the tax reform act. Very generally, these sections deny U.S. tax deductions associated with a financial instrument, transaction, or entity that is treated differently under the tax laws of the US and the tax laws of another country. • Such an instrument, transaction, or entity is referred to as a “hybrid”; and sections 267A and 245A(e) are referred to as “anti-hybrid” provisions. • Hybrids, by exploiting the differences between tax laws, can be used to claim tax benefits in multiple countries or achieve “double nontaxation”. • The Proposed Regulations will generally be retroactively effective from January 1, 2018 if they are finalized by June 22, 2019. If they are not finalized by then, they will be effective as of December 20, 2018.