To prohibit the Secretary of the Treasury from issuing regulations dealing with hybrid transactions.

Prohibits the Secretary of the Treasury under provisions of subpart F (Controlled Foreign Corporations) of part III (Income from Sources Without the United States) of subchapter N (Tax Based On Income From Sources Within or Without the United States) of the Internal Revenue Code from, among other things, issuing either temporary or final regulations relating to the treatment of hybrid transactions. Requires a study and report concerning such transactions.