### Question
Can you define what U.S. debt hybrid instrument means?


### Answer
**U.S. debt hybrid instrument** is defined as the following in *26 CFR § 1.909-2T*:

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

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

