id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-359	Wells, Bret	Economic Substance Doctrine: How Codification Changes Decided Cases	2022	47	.pdf	application/pdf	20302	879	50	An entity that is treated as an entity for tax purposes in a foreign jurisdiction but is disregarded as a separate taxpayer for U.S. tax purposes is referred to in the tax literature as a “hybrid entity.” The Treasury Department has responded in an ad hoc manner to foreign tax credit generator transactions.	cache/ftr-359.pdf	txt/ftr-359.txt