SIFMA provides comments to the U.S. Department of Treasury and the Internal Revenue Service (IRS) requesting guidance on implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) relating to the tax treatment of derivative positions assumed by affiliated entities.  SIFMA writes to seek express confirmation (in the form of a notice or otherwise) that the assumption of a derivative position by a related derivatives dealer does not cause the assignor’s counterparty to be deemed, for tax purposes, to have terminated its position and entered into a new one.