### Question
How does the law define reverse hybrid?


### Answer
Under *26 CFR § 1.909-2T*, **reverse hybrid** is defined as:

> an entity that is a corporation for U.S. Federal income tax purposes but is a fiscally transparent entity (under the principles of § 1.894-1(d)(3)) or a branch under the laws of a foreign country imposing tax on the income of the entity.

#### Citation:
  - *26 CFR § 1.909-2T*
  - Heading: **PART 1—INCOME TAXES (CONTINUED) > CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED)**

