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Proposed Treasury Regulations Under Section 385

The U.S. Treasury, in April, issued a proposal: Treatment of Certain Interests in Corporations as Stock or Indebtedness.  This could have sweeping implications for many routine treasury activities such as cash concentration, cash pooling, inter-company lending and in house banks.  We believe the language of the rule extends well beyond the intent of the Department of the Treasury.

Treasury Strategies, a division of Novantas, Inc., is advocating on behalf of the corporate treasurers by submitting this comment letter to Secretary Lew today with our analysis and a proposed path forward.

Treasury Strategies

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