Nicholas Mowbray Article Examines Anti-Hybrid, Anti-Conduit Rules

Articles / July 23, 2020

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).

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