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Comment Letter to U.S. Treasury on Proposed Regulation Rule 385

Treasury Strategies, a division of Novantas, Inc., has provided its comments to the US Treasury on the issued proposal — Rule 385 — Treatment of Certain Interests in Corporations as Stock or indebtedness, outlining how the proposed rule, designed to thwart tax inversions is overly broad and would have significant damage to corporations and banks.

The Honorable Jacob Lew Department of the Treasury c/o Internal Revenue Service P.O. Box 7604, Ben Franklin Station Washington, DC 20044 Attention: CC: PA:LPD:PR (REG-108060-15) Room 5203 Re: Proposed Treasury regulations under Section 385 Dear Secretary Lew: Treasury Strategies, a division of Novantas, Inc. is pleased to share our concerns regarding the proposed regulation (REG-108060-15). Treasury Strategies is the acknowledged leader in treasury, liquidity and payments issues. These are precisely the areas that are impacted by this proposal. For 34 years, we have consulted with corporations, municipalities, and financial services providers in the U.S. and around the world on these ...

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