### Question
How does PART 1—INCOME TAXES (CONTINUED) define U.S. debt hybrid instrument?


### Answer
Under *26 CFR § 1.909-2*, **U.S. debt hybrid instrument** is defined as:

> an instrument that is treated as equity for foreign tax purposes but as indebtedness for U.S. Federal income tax purposes.

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

