National and International Tax Issues

Reviews of current and proposed taxes in the financial sector that may impact OTC derivatives.


DateTitle / DescriptionDocuments
July 27, 2016
ISDA Comment letter supporting delay of implementation date for 871(m)
ISDA comment letter to the United States Department of the Treasury in support of comments submitted by the Securities Industry and Financial Markets Association (SIFMA) in its June 24th letter seeking a delay of the implementation date for the final and temporary regulations under section 871(m) of the Internal Revenue Code.
DCDOCS01-#429042-v1-Section_871(m)_Effective_Date_Letter_FINAL.pdf
March 11, 2016
ISDA Comment on proposed regulations concerning notional principal contracts with nonperiodic payments
ISDA comment letter to the United States Department of the Treasury regarding the proposed regulations concerning notional principal contracts with nonperiodic payments published on May 8, 2015.
Nonperiodic_swap_payment_ISDA_letter.pdf
June 19, 2015
ISDA Comment on temporary regulations concerning notional principal contracts with nonperiodic payments
ISDA comment letter to the United States Department of the Treasury requesting a delay in the effective date of the temporary regulations concerning notional principal contracts with nonperiodic payments published on May 8, 2015 in Treasury Decision 9719.
ISDA_-_Effective_Date_Letter - FINAL 06 18 15.pdf
February 10, 2015
ISDA Comment on Section 871(m) Regulations
ISDA comment letter to the United States Department of the Treasury requesting a delay in the application of final regulations under Section 871(m).
871m_Request_for_Delay_in_the_Application_of_Final_Regulations.pdf
June 12, 2014
Joint letter from ISDA’s North American Tax Committee together with CME Group, SIFMA and FIA to the United States Department of the Treasury and Internal Revenue Service requesting guidance and relief relating to upfront payments on certain types of swap transactions.
Joint letter from ISDA’s North American Tax Committee together with CME Group, SIFMA and FIA to the United States Department of the Treasury and Internal Revenue Service requesting guidance and relief relating to upfront payments on certain types of swap transactions.
CME-SIFMA-ISDA-FIA -- Comment Letter re Swap Upfront Payments.pdf
May 16, 2014
ISDA Comments on Proposed Section 871(m) Regulations
ISDA comment letter to the United States Department of the Treasury and Internal Revenue Service on proposed Section 871(m) regulations.
DCDOCS01-%23415237-v6-ISDA_-_Section_871%28m%29_Comment_Letter.pdf
February 28, 2014
ISDA North America Tax Committee Comment Letter to U.S. Treasury requesting a delay in the application of proposed regulations under Section 871(m) of the Internal Revenue Code
The submission to the United States Treasury requests immediate relief from the early application of recently proposed Treasury regulations under Internal Revenue Code section 871(m) to U.S. equity-linked derivative transactions.
DCDOCS01-%23413836-v1-Revised_ISDA_Letter_2-28 DOC.pdf
November 25, 2013
Financial Transaction Tax: The Impacts and Arguments – A Literature Review
Literature review distilling the main points from a large body of literature that has been generated to date on the European Commission’s proposal for a harmonised FTT. The report was commissioned by a group of 27 trade associations, financial market organisations and business groups.
FTT Literature Review (final).pdf
January 23, 2013
ISDA letter to the Italian Authorities regarding Financial Transactions Tax
ISDA letter regarding the Financial Transactions Tax introduced by the Italian Parliament, which was approved at the end of December 2012
ISDA_Letter_on_Italian_FTT_final.pdf
September 4, 2012
ISDA Comments on Proposed FATCA Regulations
ISDA comment letter to the United States Department of the Treasury and Internal Revenue Service on the proposed regulations issued on February 15, 2012 by the Treasury Department pursuant to Sections 1471-1474 of the Internal Revenue Code of 1986, as amended, commonly referred to as “FATCA”.
20120904 ISDA FATCA Comment Letter FINAL.pdf