AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Proposed rule; notice of hearing.

SUMMARY:

This document provides a notice of public hearing on proposed regulations to implement sections 245A(e) and 267A of the Internal Revenue Code (Code) regarding hybrid dividends and certain amounts paid or accrued in hybrid transactions or with hybrid entities, and to provide rules under sections 1503(d) and 7701 of the Code to prevent the same deduction from being claimed under the tax laws of both the United States and a foreign country.

DATES:

The public hearing is being held on Wednesday, March 20, 2019, at 10 a.m. The IRS must receive speakers' outlines of the topics to be discussed at the public hearing by Friday, March 15, 2019.

ADDRESSES:

The public hearing is being held in the IRS Auditorium, Internal Revenue Service Building, 1111 Constitution Avenue NW, Washington, DC 20224. Due to building security procedures, visitors must enter at the Constitution Avenue entrance. In addition, all visitors must present a valid photo identification to enter the building.

Send Submissions to CC:PA:LPD:PR (REG-104352-18), Room 5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand-delivered Monday through Friday to CC:PA:LPD:PR (REG-104352-18), Couriers Desk, Internal Revenue Service, 1111 Constitution Avenue NW, Washington, DC 20224 or sent electronically via the Federal eRulemaking Portal at www.regulations.gov (IRS REG-104352-18).

FOR FURTHER INFORMATION CONTACT:

Concerning the proposed regulations, contact Tracy Villecco at (202) 317-3800; concerning submissions of comments, the hearing and/or to be placed on the building access list to attend the hearing, Regina L. Johnson at (202) 317-6901 (not toll free numbers) or fdms.database@irscounsel.treas.gov.