SIFMA provides comments to the U.S. House Ways and Means Committee on the Committee’s Financial Products Discussion Draft (the Draft) released on January 24, 2013.  SIFMA shares its views on tax policy issues, administrative issues and, importantly, business related issues that are of most significance to the financial services industry and to individual investors. SIFMA believes some of the proposals are sensible but require some minor revisions, while other proposals, including the mark-to-market and average basis proposals, raise significant business, policy, and administrative issues that warrant further consideration. In the case of the mark-to-market proposal (the MTM Proposal), the definition of a “derivative” that is subject to mark-to-market treatment as drafted is very broad and in SIFMA’s opinion needs to be narrowed and further refined so that it is better targeted.

SIFMA’s White Paper: Tax Position Overview as Prepared for the US House Ways and Means Committee