(A) through (H). (3) Underlying investment The term underlying investment means, with respect to any derivative, any item— (A) which is described in any of the subparagraphs (A) through (H) of paragraph (2) (or any item substantially the same as any such item), and (B) by reference to which the value of the derivative, or any payment or other transfer with respect to the derivative, is determined either directly or indirectly. (4) Treatment of exchanges (A) In general An exchange shall be treated as the sale of the property transferred and a purchase of 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), (C), or (E) 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 60 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)), the broker. (2) Special rules for direct, etc., transactions In the case of any transaction to which paragraph (1)