### Question
How does PART 1—INCOME TAXES (CONTINUED) define U.S. equity hybrid instrument?


### Answer
Under *26 CFR § 1.909-2*, **U.S. equity hybrid instrument** is defined as:

> an instrument that is treated as equity for U.S. Federal income tax purposes but for foreign income tax purposes either is treated as indebtedness or otherwise entitles the issuer to a deduction with respect to such instrument.

#### Citation:
  - *26 CFR § 1.909-2*
  - Heading: **PART 1—INCOME TAXES (CONTINUED)**

