Associate Nicholas Mowbray co-authored an article published July 13, 2020, in the Journal of Taxation of Financial Products. The article, “When the Anti-Conduit Rules Became Synonymous with Anti-Hybrid Rules: A Discussion of Proposed Reg. §1.881-3,” examines anti-hybrid rules, proposed anti-conduit rules, and the IRS and Treasury Department’s approach to issuing taxpayer guidance.
Read the article (registration required).