### Question
What is the definition of U.S. debt hybrid instrument?


### Answer
The definition of **U.S. debt hybrid instrument** is as follows in *26 CFR § 1.909-2*:

> 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)**

