1) Foreign tax credits are limited in proportion to a resident taxpayer's net 
income under domestic law, thus limiting the benefits of hybrid transfers such as that described in Recommendation 2.2. There is however an argument that the limitation does not apply under certain double taxation agreements.2) Reverse hybrids are treated as transparent locally if treated as transparent in the non-resident jurisdiction. If not transparent locally the CFC rules could apply.3) Reverse hybrids are generally treated as transparent locally, but there are some restrictions to limit such transparency to the extent that income is distributed in the year that it accrues to the reverse hybrid entity.4) Deeming provisions classify debt and equity hybrid financial instruments so as to align their treatment with their economic substance.