Date: December 18, 2015
Issue: Tax
To: Treasury Department
Filing Type: Regulatory
Description: This letter is a follow up to CCMC's letter of September 8, 2015 to the IRS regarding a potential reinterpretation of Internal Revenue Code (“IRC”) Section 305(c). That letter respectfully requested that (1) the publication of a proposal for notice and comment contain an economic analysis that includes a study of the impacts upon capital formation for American businesses; and (2) that any reinterpretation of IRC Section 305(c) not be applied retroactively.