The "Hybrid" company : an alternative to trusts and foundations

Abstract

This dissertation proposes to give the reader an insight into the 'hybrid' company and the considerable potential of this corporate vehicle, particularly in the context of modern day estate planning and international tax planning. The appellation 'hybrid' company is given by international practitioners to the company limited by guarantee and having a share capital, as distinct from the term 'hybrid entity' with which international tax practitioners will undoubtedly be familiar, in that it denotes an entity which is treated as a corporation (akin to the UK concept of a 'company') for foreign tax purposes, but as a partnership for US tax purposes.