SIFMA, the Financial Services Forum, The Financial Services Roundtable (FSR), the Investment Company Institute (ICI), and the U.S. Chamber of Commerce provide comments to the European Commission expressing serious concerns related to the extraterritorial impact in the United States and other countries of the European Commission’s draft Council Directive implementing enhanced cooperation in the area of financial transaction tax.   The groups point out the Directive would introduce both a residency and issuance test for taxation, which are both unprecedented and inconsistent with existing norms of international tax law and long-standing treaty commitments.