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Comments on the Discussion Draft of the "Modernization of Derivatives Tax Act of 2016"

OCC and the U.S. Securities Markets Coalition provided preliminary comments on the discussion draft of the Modernization of Derivatives Tax Act of 2016. While OCC and the Coalition agree with Senator Wyden's stated interest in creating "one fair system with simple and straightforward rules," they do not believe the discussion draft would advance those objectives, but instead would create results that are neither fair, nor simple, nor straightforward as applied to exchange-traded options.

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