Single Stock Equity Swaps on Publicly Traded Equities of US Corporations

SIFMA provides comments to the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) on single stock equity swaps on publicly traded equities of U.S. corporations.  SIFMA requests Treasury and the IRS issue public guidance for taxpayers to follow to ensure that their equity swap transactions are subject to the default sourcing rule and not subject to recharacterization.