Hybrids Left Out of IRS Final Rules on Conduit Financing Arrangements

For over 50 years, Bloomberg BNA’s renowned flagship daily news service, Daily Tax Report® has helped leading practitioners and policymakers stay on the cutting edge of taxation and...

IRS finalizes rules on conduit financing arrangements with minor changes that do not address the controversial issue of hybrid instruments. The government says the final rules (T.D. 9562) contain only small changes to an example in the proposed regulations (REG-113462-08). However, it says, IRS continues to study how best to approach hybrid conduit arrangements. The rules keep in place IRS's proposal to amend the existing conduit financing regulations to address an entity disregarded as an entity separate from its owner for U.S. tax purposes.