The Federal Taxation Committee of the Securities Industry Association (SIA)* provides comments to the U.S. Department of Treasury and the Internal Revenue Service (IRS) on the recent submission of the Ad Hoc Coalition on Intermarket Coordination concerning guidance on constructive sales under Section 1259 of the Internal Revenue Code (the Code).  SIA disagrees with the conclusions reached in the Coalition’s submission, and details specific concerns on several important aspects.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.