May 30, 2023

VIA ELECTRONIC SUBMISSION

Ms. Hillary Salo
Technical Director, FASB
801 Main Avenue
PO Box 5116
Norwalk, CT 06856-5116

Re: File Reference No. 2023-ED100, Improvements to Income Tax Disclosures (Topic 740)

Dear Ms. Salo,

SIFMA submits this letter to the Financial Accounting Standards Board (the “Board”) in response to the proposed accounting standards update Income Taxes (Topic 740): Improvements to Income Tax Disclosures. We appreciate the opportunity to provide feedback and support the Board’s ongoing efforts to provide financial statement users with decision-useful information by improving the effectiveness of disclosures.

I. Executive Summary
While SIFMA understands the Board’s objectives and are supportive of several of the proposed amendments, we believe that certain aspects should be reconsidered because the intended benefits are not likely to be achieved with the proposed disclosures. Specifically,

• The prescribed categories and granular disaggregation in the effective tax rate reconciliation would present users with incremental disclosures that are not decision-useful in most cases.

 

1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).