Treaty Guidance Regarding Payments with
Respect to Domestic Reverse Hybrid Entities

DEPARTMENT OF THE TREASURY
Internal Revenue Service 26 CFR Part 1 [REG-107101-00] RIN 1545-AY13

TITLE: Treaty Guidance Regarding Payments With Respect to Domestic
Reverse Hybrid Entities

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking and notice of public hearing.

SUMMARY: This document contains proposed regulations under section
894 of the Internal Revenue Code relating to the eligibility for
treaty benefits of items of income paid by domestic entities that
are not fiscally transparent under U.S. law but are fiscally
transparent under the laws of the jurisdiction of the person
claiming treaty benefits (a domestic reverse hybrid entity). The
proposed regulations affect the determination of tax treaty benefits
with respect to U.S. source income of foreign persons. This document
also provides notice of a public hearing on these proposed
regulations.

DATES: Written or electronic comments must be received by May 29,
2001. Requests to speak (with outlines of oral comments to be
discussed) at the public hearing scheduled for June 26, 2001, at 10
a.m., must be submitted by June 5, 2001.

ADDRESSES: Send submissions to: CC:M&SP:RU (REG-107101-00), room
5226, Internal Revenue Service, POB 7604, Ben Franklin Station,
Washington, DC 20044. Submissions may be hand delivered between the
hours of 8 a.m. and 5 p.m. to:

CC:M&SP:RU (REG-107101-00), Courier's Desk, Internal Revenue
Service, 1111 Constitution Avenue, NW., Washington, DC.
Alternatively, taxpayers may submit comments electronically via the
Internet by selecting the "Tax Regs" option on the IRS Home Page, or
by submitting comments directly to the IRS Internet site at
http://www.irs.gov/prod/tax_regs/regslist.html. The public hearing
will be held in the auditorium, Internal Revenue Building, 1111
Constitution Avenue, NW., Washington, DC.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations,
Elizabeth U. Karzon or Karen Rennie-Quarrie at (202) 622-3880;
concerning submissions and the hearing, Guy R. Traynor at (202)
622-7180 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

On June 30, 1997, the IRS and Treasury issued temporary regulations
(TD 8722 [1997-2 C.B. 81]) in the ederal Register (62 FR 35673, as
corrected at 62 FR 46876, 46877) under section 894 of the Internal
Revenue Code relating to eligibility for benefits under income tax
treaties for payments to certain entities. These regulations
addressed, among other matters, the eligibility for treaty benefits
of U.S. source payments made to domestic reverse hybrid entities,
concluding that treaty benefits were not available for such
payments. A notice of proposed rulemaking ([1997-2 C.B. 646]) cross-
referencing the temporary regulations was also published in the same
issue of the ederal Register (62 FR 35755). On July 3, 2000, the IRS
and Treasury issued final regulations (TD 8889), reaffirming the
position taken in the temporary regulations. with respect to
payments made to domestic reverse hybrid entities. The final
regulations, however, did not address the question of whether
payments made by domestic reverse hybrid entities to their interest
holders are eligible for treaty benefits. Section 1.894-1(d)(2)(ii)
was reserved for further guidance on that issue.

Explanation of Provisions

These proposed regulations provide guidance with respect to the
previously reserved paragraph. They provide rules on the character
of such payments for treaty purposes and the extent to which such
payments are eligible for a reduced rate of U.S. tax under a U.S.
income tax treaty. The use of domestic reverse hybrid entities may
give rise to inappropriate and unintended results under income tax
treaties, such as double non-taxation or double taxation, unless the
income tax treaties are interpreted to resolve the conflict of laws.
These regulations provide guidance regarding how to apply U.S.
income tax treaties under these circumstances.

Section 1.894-1T(d)(3) provided guidance on the appropriate
treatment of items of income paid to a domestic reverse hybrid
entity. That section provided that §1.894- 1T(d)(1) may not be
applied to reduce the amount of Federal income tax on U.S. source
income received by a domestic reverse hybrid entity through
application of an income tax treaty. Thus, neither the domestic
reverse hybrid entity nor its interest holders could claim a
reduction under an income tax treaty with respect to a payment to a
domestic reverse hybrid entity, notwithstanding that the interest
holder might otherwise derive the income as a resident of a treaty
jurisdiction under §1.894-1T(d)(1). The rationale for the rule
was the U.S. tax treaty principle that the United States retains.
taxing jurisdiction over items of U.S. source income paid to its
residents. The final regulations published in the ederal Register on
July 3, 2000, retain the rule that a domestic reverse hybrid entity
remains subject to the taxing jurisdiction of the United States on
U.S. source payments, but reserve with respect to the treatment of
payments made by domestic reverse hybrid entities.

Commentators on the previously issued temporary and proposed
regulations noted that it was unclear how items of income paid by a
domestic reverse hybrid entity to its interest holders should be
treated. In particular, the general rule contained in §1.894-
1T(d) (1) required the item of income to be "received by" a person
resident in a treaty jurisdiction and for that item of income to be
"subject to tax" in the hands of the person deriving the item of
income. Commentators expressed concern that an item of income paid
by a domestic reverse hybrid entity could be viewed as neither
"received by" the interest holder nor "subject to tax" because the
interest holder's jurisdiction treats the domestic reverse hybrid
entity as fiscally transparent. The interest holder's jurisdiction
views the interest holder as "receiving" the items of income paid to
the domestic reverse hybrid entity and as being "subject to tax" on
those items of income on an immediate basis. The interest holder's
jurisdiction does not recognize the items of income paid by the
domestic reverse hybrid entity to the interest holder. Based on this
analysis, commentators questioned whether the items of income paid
by the domestic reverse hybrid entity to an interest holder in that
entity would be subject to a 30-percent tax under the Code. The IRS
and Treasury believe similar questions may also arise under the
recently issued final regulations.

Accordingly, these proposed regulations provide rules on the
treatment of payments made by domestic reverse hybrid entities.
Paragraph (d)(2)(ii) of this section provides a general rule that an
item of income paid by a domestic reverse hybrid entity to an
interest holder shall be characterized under U.S. tax law. This
means that U.S. tax principles are first applied to characterize the
item of income paid by the domestic reverse hybrid entity to the
interest holder for purposes of applying an applicable income tax
treaty provision. Once the item of income is so characterized, it is
necessary to determine if the interest holder derives the item of
income. In determining whether the interest holder derives the item
of income, paragraph (d)(2)(ii)(A) of this section provides a
special rule for determining whether the interest holder is fiscally
transparent with respect to the item of income. Under that rule,
whether the interest holder is fiscally transparent with respect to
the item of income for purposes of §1.894- 1(d)(3)(ii) is made
based on the treatment that would have resulted had the item of
income been paid by an entity that was not fiscally transparent
under the laws of the interest holder's jurisdiction with respect to
any item of income.Accordingly, if the interest holder is not
fiscally transparent, then it will be considered to have derived the
item of income, even if, for example, the item of income were
characterized differently or treated as received at an earlier date
under the laws of the interest holder's jurisdiction than the item
of income paid by the domestic reverse hybrid entity.

The IRS and Treasury have learned, however, that domestic reverse
hybrid entities are being established by related parties to
manipulate differences in U.S. and foreign entity classification
rules to reduce inappropriately the amount of tax imposed on items.
of income paid from the United States to related foreign interest
holders. In a typical scenario, a foreign investor, resident in a
treaty jurisdiction, establishes a domestic reverse hybrid holding
company with a combination of debt and equity contributions. The
domestic reverse hybrid entity holds the stock of a wholly-owned
U.S. operating company. The operating company pays a dividend to the
domestic reverse hybrid entity, but the domestic reverse hybrid
entity primarily pays interest to its foreign owner within the
earning stripping limits of section 163(j). The foreign jurisdiction
views the foreign owner as receiving dividends, but the United
States views the domestic reverse hybrid entity as receiving the
dividends and making deductible interest payments. In circumstances
when the income tax treaty between the United States and the
applicable foreign jurisdiction applies a zero withholding rate on
interest and a 5- percent rate on related party dividends, the
domestic reverse hybrid entity treats its payment to the foreign
owner as an interest payment and the foreign owner avoids the
withholding tax on the dividends that its jurisdiction treats it as
receiving. In addition, the domestic reverse hybrid entity receives
the benefit of an interest deduction in the United States while the
foreign interest holder receives either a tax credit or exclusion on
the dividend amount in its jurisdiction.

The IRS and Treasury believe that it is inappropriate for related
parties to use domestic reverse hybrid entities for the purpose of
converting higher taxed U.S. source items of income to lower taxed,
or untaxed, U.S. source items of income. To do so defeats the
expectation of the United States and its treaty partners that
treaties should be used to reduce or eliminate double taxation for
legitimate transactions, not to reward. the manipulation of
inconsistencies in the laws of the treaty partners. The legislative
history of section 894(c) supports this analysis. Congress
specifically expressed its concern about the potential tax avoidance
opportunities available for foreign persons that invest in the
United States through hybrid entities that are designed to avoid
both U.S. and foreign income taxes. See H.R. Conf. Rep. No 220, 105
Cong, 1 Sess. 573 (1997); Joint Committee on Taxation, 105 Cong., 1
Sess., General Explanation of Tax Legislation Enacted in 1997
(JCS-23-97), at 249 (December 17, 1997). The approach contained in
§1.894-1(d)(2), as revised, is also consistent with the general
tax treaty principle that contracting states may adopt provisions in
their domestic laws to counter structures and transactions intended
to take advantage of the differences in the tax laws of the
contracting states. See Commentaries to Article 1 of The 1998 OECD
Model Tax Convention on Income and Capital; S. Rep. No. 445, 100
Cong. 2d Sess. 322-23 (1988).

The IRS and Treasury are further concerned by the ability of foreign
acquiring entities to obtain tax advantaged financing through
domestic reverse hybrid entities by exploiting differences between
U.S. and foreign law. Such financing unfairly disadvantages
similarly situated U.S. domestic acquiring entities. Congress has
expressed concern about the use of analogous hybridized structures
that were effected to provide foreign acquiring entities with tax
advantaged acquisition financing not available to similarly situated
domestic companies. See Joint Committee on Taxation, 100th Congress,
1 Sess., General Explanation of the Tax Reform Act of 1986 (JCS-
10-87), at 1064, 1065 (May 4, 1987).

For these reasons, the proposed regulations provide a special rule
in paragraph (d)(2)(ii)(B) of the regulations,such that if: (1) a
domestic entity makes a payment to a related domestic reverse hybrid
entity that is considered to be a dividend either under the laws of
the United States or under the laws of the jurisdiction of a related
foreign interest holder in the domestic reverse hybrid entity, and
the related foreign interest holder is treated as deriving its
proportionate share of the payment to the domestic reverse hybrid
entity under the laws of the related foreign interest holder's
jurisdiction; and (2) the domestic reverse hybrid entity makes a
payment to the related foreign interest holder of a type that is
deductible for U.S. tax purposes and for which a reduction in the
U.S. withholding tax rate would be allowed under the general rule,
but for this exception, then to the extent the amount of the payment
by the domestic reverse hybrid entity to the related foreign
interest holder does not exceed the total amount of the interest
holder's proportionate share of any payments by the domestic entity
to the domestic reverse hybrid entity treated as dividends under
either jurisdiction's laws, the payment by the domestic reverse
hybrid entity shall be treated as a dividend for all purposes of the
Code and the applicable income tax treaty.

For purposes of determining the amount of the payment from the
domestic reverse hybrid entity to the related foreign interest
holder to be recharacterized as a dividend, the portion of the
payments treated as derived by the related foreign interest holder
shall be reduced by the amount of any prior actual dividend
payments, under U.S. law, made by the domestic reverse hybrid entity
to the related foreign interest holder and by the amount of any
payments from the domestic reverse hybrid entity to the related.
foreign interest holder previously recharacterized under this
special rule. The tax withheld from the payment from the domestic
reverse hybrid entity to the related foreign interest holder shall
be determined based on the appropriate rate of withholding that
would be applicable to dividends paid by the domestic reverse hybrid
entity to the related foreign interest holder under the U.S. treaty
with the related foreign interest holder's jurisdiction had that
jurisdiction viewed the domestic reverse hybrid entity as not
fiscally transparent. Because any payment subject to the provisions
of this special rule is treated as a dividend for all purposes of
the Code and the applicable treaty, the domestic reverse hybrid
entity will not be able to claim a deduction on the payment to the
related foreign interest holder.

The regulations provide an 80% ownership test to determine if the
parties are related to one another and a special rule that treats
accommodation parties as related foreign interest holders. The
foregoing rules also apply to recharacterize payments when more than
one domestic reverse hybrid entity or other fiscally transparent
entity is involved. The proposed regulations further provide that a
taxpayer may not affirmatively use the rules of paragraph (d)(2) of
this section if a principal purpose for using such rules is the
avoidance of any tax imposed by the Code. Thus, with respect to such
a taxpayer, the Commissioner may depart from the rules of this
section and recharacterize (for all purposes of the Code) the
arrangement in accordance with its form or its economic substance.
The regulations further provide that, if a taxpayer enters into an
arrangement the effect of which is to circumvent the principles of
this paragraph (d)(2), the Commissioner may recharacterize (for all
purposes of the Code) the arrangement in accordance with the
principles of this paragraph (d)(2).

Comments are requested on potential rules with respect to
transaction when the domestic reverse hybrid entity is sold to
unrelated parties who later receive distributions.

Proposed Effective Dates

These proposed regulations apply to items of income paid by a
domestic reverse hybrid entity on or after the date these
regulations are published as final regulations in the ederal
Register with respect to amounts received by the domestic reverse
hybrid entity on or after the date these regulations are published
as final regulations in the ederal Register. No inference is
intended as to the treatment of transactions entered into prior to
the date of applicability of the final regulations.

Special Analysis

It has been determined that this notice of proposed rulemaking is
not a significant regulatory action as defined in Executive Order
12866. Therefore, a regulatory assessment is not required. It has
also been determined that section 553(b) of the Administrative
Procedure Act (5 U.S.C. chapter 5) does not apply to these
regulations and, because these regulations do not impose on small
entities a collection of information requirement, the Regulatory
Flexibility Act (5 U.S.C. chapter 6) does not apply. Therefore, a
Regulatory Flexibility Analysis is not required.Pursuant to section
7805(f) of the Code, this notice of proposed rulemaking will be
submitted to the Chief Counsel for Advocacy of the Small Business
Administration for comment on its impact. on small business.

Comments and Public Hearing

Before these proposed regulations are adopted as final regulations,
consideration will be given to any written comments (preferably a
signed original and eight (8) copies) that are submitted timely to
the IRS. The IRS and Treasury Department specifically request
comments on the clarity of the proposed regulations and how they can
be made easier to understand. All comments will be available for
public inspection and copying.

A public hearing has been scheduled for June 26, 2001, at 10 a.m. in
the auditorium, Internal Revenue Building, 1111 Constitution Avenue,
NW., Washington, DC. Because of access restriction, visitors will
not be admitted beyond the Internal Revenue Building lobby more than
15 minutes before the hearing starts. The rules of 26 CFR 601.601(a)
(3) apply to the hearing.

Persons that wish to present oral comments at the hearing must
submit written comments by May 29, 2001, and submit an outline of
the topics to be discussed and the time to be devoted to each topic
(preferably a signed original and eight (8) copies) by June 5, 2001.

A period of 10 minutes will be allotted to each person for making
comments. An agenda showing the scheduling of the speakers will be
prepared after the deadline for receiving outlines has passed.
Copies of the agenda will be available free of charge at the
hearing.

Drafting Information

The principal author of these regulations is Shawn R. Pringle of the
Office of the Associate Chief Counsel (International). However,
other personnel from the IRS and Treasury Department participated in
their development.

List of Subjects in 26 C R Part 1

Income taxes, Reporting and recordkeeping requirments.

Proposed Amendments to the Regulations

Accordingly, 26 CFR part 1 is proposed to be amended as follows:

PART 1--INCOME TAXES

Paragraph 1. The authority for part 1 continues to read in part as
follows:

Authority: 26 U.S.C. 7805 * * *

Section 1.894-1(d)(2) also issued under 26 U.S.C. 894 and 7701(1). 

Par. 2. In §1.894-1, paragraph (d)(2)(ii) is revised and
paragraphs (d)(2)(iii) and (d)(2)(iv) are added to read as follows:

§1.894-1 Income affected by treaty.

* * * * *

(d) * * *

(2) * * *

(ii) Payments by domestic reverse hybrid entities--

(A) General rule. Except as otherwise provided in paragraph (d)(2)
(ii)(B) of this section, an item of income paid by a domestic
reverse hybrid entity to an interest holder in such entity shall
have the character of such item of income under U.S. law and shall
be considered to be derived by the interest holder, provided the
interest holder is not fiscally transparent in its. jurisdiction, as
defined in paragraph (d)(3)(iii) of this section, with respect to
the item of income. In determining whether the interest holder is
fiscally transparent with respect to the item of income under this
paragraph (d)(2)(ii)(A), the determination under paragraph (d)(3)
(ii) of this section shall be made based on the treatment that would
have resulted had the item of income been paid by an entity that is
not fiscally transparent under the laws of the interest holder's
jurisdiction with respect to any item of income.

(B) Payment made to related foreign interest holder--

(1) General rule. If--

(i) A domestic entity makes a payment to a related domestic reverse
hybrid entity that is treated as a dividend under either the laws of
the United States or the laws of the jurisdiction of a related
foreign interest holder in the domestic reverse hybrid entity, and
under the laws of the jurisdiction of the related foreign interest
holder in the domestic reverse hybrid entity, the related foreign
interest holder is treated as deriving its proportionate share of
the payment under the principles of paragraph (d)(1) of this
section; and

(ii) The domestic reverse hybrid entity makes a payment of a type
that is deductible for U.S. tax purposes to the related foreign
interest holder and for which a reduction in the U.S. withholding
tax rate would be allowed under paragraph (d)(2)(ii)(A) of this
section but for this paragraph (d)(2)(ii)(B), then

(iii) To the extent the amount of the payment described in paragraph
(d)(2)(ii)(B)(1)(ii) of this section does not exceed the sum of the
portion of the payment described in paragraph (d)(2)(ii)(B)(1)(i) of
this section treated as derived by the related. foreign interest
holder and the portion of any other prior payments described in
paragraph (d)(2)(ii)(B)(1)(i) of this section treated as derived by
the related foreign interest holder, the amount of the payment
described in (d)(2)(ii)(B)(1)(ii) of this section will be treated
for all purposes of the Internal Revenue Code and the applicable
income tax treaty as a dividend, and the tax to be withheld from the
payment described in paragraph (d)(2)(ii)(B)(1)(ii) of this section
shall be determined based on the appropriate rate of withholding
that would be applicable to dividends paid from the domestic reverse
hybrid entity to the related foreign interest holder under the U.S.
treaty with the related foreign interest holder's jurisdiction had
that jurisdiction viewed the domestic reverse hybrid entity as not
fiscally transparent; and

(iv) For purposes of determining the amount to be recharacterized
under paragraph (d)(2)(ii)(B)(1)(iii) of this section, the portion
of the payments described in paragraph (d)(2)(ii)(B)(1)(i) of this
section treated as derived by the related foreign interest holder
shall be reduced by the amount of any prior actual dividend payments
made by the domestic reverse hybrid entity to the related foreign
interest holder and by the amount of any payments from the domestic
reverse hybrid entity to the related foreign interest holder
previously rechacterized under paragraph (d)(2)(ii)(B)(1)(iii) of
this section.

(2) Tiered entities. The principles of this paragraph (d)(2)(ii)(B)
shall also apply to payments referred to in this paragraph (d)(2)
(ii)(B) made among related entities when there is more than one
domestic reverse hybrid entity or other fiscally transparent
entities involved

(3) Definition of related. Related shall mean any entity satisfying
the ownership requirements of section 267(b) or 707(b)(1), except
that 80 percent shall be substituted for 50 percent. For purposes of
determining whether a person is related to another person, the
constructive ownership rules of section 318 shall apply, and the
attribution rules of section 267(c) also shall apply to the extent
they attribute ownership to persons to whom section 318 does not
attribute ownership. If a person enters into a transaction (or
series of transactions) with the domestic reverse hybrid entity, its
related interest holders, or its related entities, and the effect of
the transaction (or series of transaction) is to avoid the
principles of this paragraph (d)(2)(ii)(B), then that person shall
be treated as related to the domestic reverse hybrid entity for
purposes of this section.

(c) Commissioner's discretion. The Commissioner may, as the
Commissioner determines to be appropriate, recharacterize for all
purposes of the Internal Revenue Code all or part of any transaction
(or series of transactions) between related parties if the effect of
the transaction (or series of transactions) is to avoid the
principles of this paragraph (d)(2).

(iii) Examples. The rules of this paragraph (d)(2) are illustrated
by the following examples:

Example 1. Treatment of payment by unrelated entity to domestic
reverse hybrid entity.

      (i) Facts.

     Entity A is a domestic reverse hybrid entity, as defined in
paragraph (d)(2)(i) of this section, with respect to the U.S. source
dividends it receives from B, a domestic corporation to which A is
not related, within the meaning of paragraph (d)(2)(ii)(B)(3) of
this section. A's 85-percent shareholder FC is a corporation
organized under the laws of Country X, which has an income tax
treaty in effect with the United States. Under Country X law, FC is
not fiscally transparent with respect to the dividend, as defined in
paragraph (d)(3)(ii) of this section. In year 1, A receives a $100
of dividend income from B. Under Country X law, FC is treated as
deriving $85 of the $100 dividend payment received by A. The
applicable rate of tax on dividends under. the U.S.-Country X income
tax treaty is 5 percent with respect to a 10-percent or more
corporate shareholder.

(ii) Analysis. Under paragraph (d)(2)(i) of this section, the U.S.-
Country X income tax treaty does not apply to the dividend income
received by A because the income is paid by B, a domestic
corporation, to A, another domestic corporation. A remains fully
taxable under the U.S. tax laws as a domestic corporation with
regard to that item of income. Further, pursuant to paragraph (d)(2)
(i) of this section, notwithstanding the fact that under the laws of
Country X A is treated as fiscally transparent with respect to the
dividend income, FC may not claim a reduced rate of taxation on its
share of the U.S. source dividend income received by A.

Example 2. Treatment of payment by domestic reverse hybrid entity to
related foreign interest holder involving unrelated party.

      (i) Facts.

     The facts are the same as in Example 1. Both the United States
and Country X characterize the payment by B in year 1 as a dividend.
In addition, in year 2, A makes a payment of $25 to FC that is
characterized under U.S. tax laws as an interest payment to FC on a
loan from FC to A. Under the U.S.-Country X income tax treaty, the
rate of tax on interest is zero. Under Country X laws, had the
interest been paid by an entity that is not fiscally transparent
under Country X's laws with respect to any item of income, FC would
not be fiscally transparent as defined in paragraph (d)(2)(ii) of
this section with respect to the interest.

(ii) Analysis. The analysis is the same as in Example 1 with respect
to the $100 payment from B to A. With respect to the $25 payment
from A to FC, paragraph (d)(2)(ii)(B) of this section will not apply
because, although FC is related to A, A is not related to the payor
of the dividend income it received. Under paragraph (d)(2)(ii)(A) of
this section, the $25 interest income paid from A to FC in year 2
will be characterized under U.S. law as interest . Accordingly, in
year 2, FC may obtain the reduced rate of withholding applicable to
interest under the U.S.-Country X income tax treaty, assuming all
other requirements for claiming treaty benefits are met.

Example 3. Treatment of payment by domestic reverse hybrid entity to
related foreign interest holder.

      (i) Facts.

     The facts are the same as in Example 2, except the $100
dividend income received by A in year 1 is from A's wholly owned
subsidiary S.

(ii) Analysis. The analysis is the same as in Example 1 with respect
to the $100 dividend payment from S to A. However, the $25 interest
payment in year 2 by A to FC will be treated as a dividend for all
purposes of the Internal Revenue Code and the U.S.-Country X income
tax treaty because $25 does not exceed FC's share of the $100
dividend payment made by S to A ($85). Since FC is not fiscally
transparent with respect to the payment as determined under
paragraph (d)(2)(ii)(A) of this section, FC will be entitled to
obtain the reduced rate applicable to dividends under the U.S.-
Country X income tax treaty with respect to the $25 payment. Because
the $25 payment in year 2 is recharacterized as a dividend for all
purposes of the Internal Revenue Code and the U.S.-Country X income
tax treaty, A would not be entitled to an interest deduction with
respect to that payment and FC would not be entitled to claim the
reduced rate of withholding applicable to interest.

(iv) Effective date. This paragraph (d)(2) applies to items of
income paid by a domestic reverse hybrid entity on or after the date
these regulations are published as final regulations in the ederal
Register with respect to amounts received by the domestic reverse
hybrid entity on or after the date these regulations are published
as final regulations in the ederal Register.

* * * * *

Robert E Wenzel
Deputy Commissioner of Internal Revenue

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