### Question
How is the term hybrid partnership defined?


### Answer
The term **hybrid partnership** is defined in *26 CFR § 1.909-1* as the following:

> a partnership that is subject to income tax in a foreign country as a corporation (or otherwise at the entity level) on the basis of residence, place of incorporation, place of management or similar criteria.

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

