### Question
How is the "hybrid entity" defined?


### Answer
The term **hybrid entity** is defined in *26 U.S.C. § 267A* as follows -

> any entity which is either—


(1) treated as fiscally transparent for purposes of this chapter but not so treated for purposes of the tax law of the foreign country of which the entity is resident for tax purposes or is subject to tax, or


(2) treated as fiscally transparent for purposes of such tax law but not so treated for purposes of this chapter

#### Citation:
  - *26 U.S.C. § 267A*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter B-Computation of Taxable Income > PART IX-ITEMS NOT DEDUCTIBLE**

