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

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.