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


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

> an instrument that is treated as equity for U.S. Federal income tax purposes but is treated as indebtedness for foreign tax purposes, or with respect to which the issuer is otherwise entitled to a deduction for foreign tax purposes for amounts paid or accrued with respect to the instrument.

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

