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The Canada-US Tax Treaty Protocol: Where Have All The Hybrids Gone?, Tax Notes International, v.49, no.3, January 21, 2008, p.271
Author(s): Barsky, JoannaPeters, Matthew
Date:  January 21 2008
Hybrid entities have become a mainstay in cross-border corporate tax planning, as evidenced by the numerous boxes containing upside-down or right-side-up triangles permeating the organizational charts of countless multinational enterprises. But are the days numbered for some of those entities as we currently know them?
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