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TCH Joins Trade Comment Letter on Adverse Tax Consequences for IHCs of Fed’s TLAC Proposal

The Clearing House (TCH) joined with SIFMA and IIB to submit a supplemental comment letter on the Fed’s Internal TLAC proposal for IHCs. The letter recommends changes to the TLAC rule to help mitigate against the risk that the internal long-term debt issued by an IHC to its foreign parent will be treated as equity for U.S. tax purposes.