TRIARC COMPANIES, INC.
                                280 Park Avenue
                               New York, NY 10017




                                                     December 19, 2006


VIA EDGAR
---------

SECURITIES AND EXCHANGE COMMISSION
Station Place
100 F Street, N.E.
Washington, D.C. 20549

ATTENTION:  HANNA T. TESHOME

            Re:   Triarc Companies, Inc.
                  Registration Statement on Form S-3
                  File No. 333-127818

Dear Ms. Teshome:

            Pursuant to Rule 461 of the Securities Act of 1933, as amended,  we
hereby  request that the  effective  date of the  above-captioned  Registration
Statement on Form S-3 (the "Registration Statement") be accelerated to December
21, 2006 at 2:00 PM Eastern time or as soon thereafter as may be practicable.

            Triarc Companies,  Inc. (the "Company")  understands that the staff
will  consider  this request as  confirmation  that the Company is aware of its
responsibilities  under the  Securities  Act and the Exchange  Act of 1934,  as
amended,  as they relate to the  proposed  public  offering  of the  securities
specified in the Registration Statement.

            The Company hereby acknowledges that:

            o   should   the   Securities   and   Exchange    Commission   (the
                "Commission")  or the  staff,  acting by  delegated  authority,
                declare  the  Registration  Statement  effective,  it does  not
                foreclose the Commission from taking any action on the filing;

            o   the action of the Commission or the staff,  acting by delegated
                authority,  in declaring the Registration  Statement effective,
                does not relieve the Company from its full  responsibility  for
                the  adequacy  and  accuracy  of the  Registration  Statement's
                disclosures; and



                                                                              2


            o   the Company may not assert the action of the  Commission or the
                staff,  acting  by  delegated   authority,   in  declaring  the
                Registration   Statement   effective,   as  a  defense  in  any
                proceedings initiated by the Commission or any person under the
                federal securities laws of the United States.

            If you have any questions  regarding the foregoing,  please contact
Raphael  M. Russo of Paul,  Weiss,  Rifkind,  Wharton &  Garrison  LLP at (212)
373-3309.

                                             Very truly yours,

                                             TRIARC COMPANIES, INC.


                                             /s/ Brian Schorr
                                             ------------------------------
                                             Brian Schorr
                                             Executive Vice President and
                                             General Counsel



cc: Raphael M. Russo, Paul, Weiss, Rifkind, Wharton & Garrison LLP