French Financial Transaction Tax
SIFMA provides comments to the French Minister of the Economy, Finance and Industry urging a postponement of the implementation date of December 1, 2012 to impose the newly enacted French Financial Transaction Tax (FFTT) on French American Depositary Receipts (ADRs). The postponement of the initial implementation date from August 1, 2012 to December 1, 2012 has been critical in allowing our member firms to analyze the FFTT requirements and work towards compliance with FFTT. SIFMA respectfully suggests that it would be in the interest of the French government not to compound the already negative market impact of the tax by denying U.S. brokers an adequate amount of time to develop and update appropriate trade management systems.