IRS Categories of Active Financing Income

SIFMA provides comments to the Internal Revenue Service (IRS) on financial services income under Section 904(d) of the Internal Revenue Code, IRS Notice 2007-58.  Because of the increased development in the regulation of securities, banking and financial industry firms, many activities that are now core to the financial services industry, and critical components of the global credit and liquidity markets, are nevertheless not explicitly mentioned on the list of activities giving rise to active financing income that is part of Treasury regulation section 1.904-4(e)(2)(i), which was issued almost twenty years ago.  SIFMA shares its observations and recommendations on new categories of active financing income that should be considered.