### Question
What is the definition of hybrid dividend?


### Answer
The definition of **hybrid dividend** is as follows in *26 U.S.C. § 245A*:

> an amount received from a controlled foreign corporation—


(A) for which a deduction would be allowed under subsection (a) but for this subsection, and


(B) for which the controlled foreign corporation received a deduction (or other tax benefit) with respect to any income, war profits, or excess profits taxes imposed by any foreign country or possession of the United States

#### Citation:
  - *26 U.S.C. § 245A*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter B-Computation of Taxable Income > PART VIII-SPECIAL DEDUCTIONS FOR CORPORATIONS**

