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.

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