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Hybrid Mismatches: Where U.S. Tax Law and A.T.A.D. Meet

Volume 5 No 8    |    Read Article

By Fanny Karaman and Beate Erwin

When U.S. tax planners attend foreign conferences, it is not uncommon to hear pointed barbs that the U.S. is an outlier when it comes to rules enforcing “best practices” on global business transactions. However, when it comes to reverse hybrids and hybrid mismatches, the rules are not all that different on both sides of the Atlantic. Fanny Karaman and Beate Erwin compare approaches taken by A.T.A.D. 2 with U.S. tax law after the Tax Cuts and Jobs Act.    See more →