the property received by each party to the exchange. (B) Certain deemed exchanges In the case of a distribution treated as an exchange for stock under section 302 or 331, the corporation making such distribution shall be treated as having purchased such stock for purposes of this section. (f) Exceptions (1) Exception for initial issues No tax shall be imposed under subsection (a) on any covered transaction with respect to the initial issuance of any security described in subparagraph (A), (B), or (C) of subsection (e)(1). (2) Exception for certain traded short-term indebtedness A note, bond, debenture, or other evidence of indebtedness which— (A) is traded on a trading facility located in the United States, and (B) has a fixed maturity of not more than 100 days, shall not be treated as described in subsection (e)(1)(C). (3) Exception for securities lending arrangements No tax shall be imposed under subsection (a) on any covered transaction with respect to which gain or loss is not recognized by reason of section 1058. (g) By whom paid (1) In general The tax imposed by this section shall be paid by— (A) in the case of a transaction which occurs or is cleared on a facility located in the United States, such facility, and (B) in the case of a purchase not described in subparagraph (A) which is executed by a broker (as defined in section 6045(c)(1)) which is a United States person, such broker. (2) Special rules for direct, etc., transactions In the case of any transaction to which paragraph (1) does not apply, the tax imposed by this section shall be paid by— (A) in the case of a transaction described in subsection (d)(1)— (i) the purchaser if the purchaser is a United States person, and (ii) the seller if the purchaser is not a United States person, and (B) in the case of a transaction described in subsection (d)(2)— (i) the payor if the payor is a United States person, and (ii) the payee if the payor is not a United States person. (h) Certain payments treated as separate transactions Except as otherwise provided