Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


Chart of AM 2025-002 (BPT Treaty Relief for Rev. Hybrid Entity With US Branch)

2025-09-21

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Last week the IRS published AM 2025-002, which addresses treaty relief from the branch profits tax for a reverse hybrid entity that had a permanent establishment in the US. Today we published a chart showing the entity structure discussed in the AM.

Tags: 882 Foreign Corps with ECI, 884 Branch Profits Tax, 894 Limitation on Benefits, 894 Permanent Establishment, 894 Treaties