hybrid dividend

(4) Hybrid dividend The term “hybrid dividend” means an amount received from a controlled foreign corporation— (A) for which a deduction would be allowed under subsection (a) but for this subsection, and (B) for which the controlled foreign corporation received a deduction (or other tax benefit) with respect to any income, war profits, or excess profits taxes imposed by any foreign country or possession of the United States.

Source

26 USC § 245A(e)(4)

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Scoping language

None identified, default scope is assumed to be the parent (part VIII) of this section.

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