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RAISING THE BAR ON BUSINESS UNIT PARTNERING UNDER ONE ROOF SHOULD TAX AND TREASURY SHARE THE SAME MASTER? + MICHAEL CONNOLLY, VICE PRESIDENT AND TREASURER AT TIFFANY & CO. MARCH 2007 www.treasuryandrisk.com
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Our expectation is that the IRS will use FAS 133, Internal Revenue Code Section 125(c) — a provision which prohibits tax-exempt organizations from contributing to political campaigns — to make that assessment, unless a donor can demonstrate that a separate campaign contribution to a 501(c)(4) organization was in fact intended as a contribution to a registered political committee on the date of the contribution. Given the limited time available for us to resolve this situation in all, it seems best to defer resolution until we can review the facts and determine what steps will be necessary. This is particularly critical given that we have been engaged in ongoing discussions with the Senate Finance Committee at their June 8/9 hearing with respect to the application of Section 125(c) to FAS 133. We therefore believe that the best course of action is to focus our limited resources on obtaining information about the situation and determining what steps should be taken. The fact that it was already the subject of some discussion within the IRS itself only reinforces our conclusion that this is a timely request and a critical event worth considering. At this time we are not aware of any facts which would provide clear indication that a prohibited campaign contribution was made because of the contribution under Section 125(c). We know our IRS and our Treasury Department personnel are very serious about determining facts and resolving this matter thoroughly. At the same time, we believe that in the absence of clear proof that a contribution was made for the sole purpose of influencing elections, we should defer further action for several months, until we have a fuller understanding of the facts. This would allow us to make recommendations that can assist in addressing such a potential situation. While we cannot be certain as to when such a situation may arise, I think it's appropriate to review this matter in all of its complexity and to consider all avenues for resolving it. We have repeatedly said that we have a comprehensive and inclusive set of policies and procedures to address any potential issue. Given that we have already taken this step in response to an allegation of illegal campaign finance activity relating to FAS 133, I think it timely to follow through on this recommendation. We will be prepared to provide the Senate Finance Committee, and the public at large, with a thorough accounting of all the IRS and Treasury guidance relating to political activities by tax-exempt organizations on or prior to January 1, 1978. I look forward to answering any questions that are raised. Respectfully, Ron. Ron J. Chatter President, Tiffany & Co.

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Integrating global treasury management refers to the process of combining and streamlining a company's treasury management functions across multiple countries or regions to improve efficiency and optimize financial operations.
Companies that operate globally or have subsidiaries in multiple countries and engage in treasury management activities are required to file integrating global treasury management.
Filling out integrating global treasury management involves providing detailed information about the company's treasury management activities, including cash flow management, risk management, foreign exchange dealings, and financial asset management.
The purpose of integrating global treasury management is to centralize and coordinate treasury functions across different countries or regions, in order to achieve greater operational efficiency, enhance risk management, and optimize cash flow and liquidity.
The information that must be reported on integrating global treasury management includes details about cash flow forecasting, foreign currency exposures, hedging strategies, liquidity management, investment policies, and compliance with regulatory requirements.
The deadline to file integrating global treasury management in 2023 is typically specified by the respective regulatory body or tax authority. Please consult the relevant guidelines or regulations for the specific deadline.
The penalty for the late filing of integrating global treasury management can vary depending on the jurisdiction. It may include financial penalties, interest charges, or other consequences as determined by the regulatory body or tax authority. It is advisable to comply with filing deadlines to avoid such penalties.
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