### Question
Can you define what reverse hybrid means?


### Answer
**Reverse hybrid** is defined as the following in *26 CFR § 1.909-2*:

> an entity that is a corporation for U.S. Federal income tax purposes but is a fiscally transparent entity (under the principles of § 1.894-1(d)(3)) or a branch under the laws of a foreign country imposing tax on the income of the entity.

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

