This letter is to provide comments on Notices 2010-60, 2011-34 and 2011-53 requesting the Internal Revenue Service consider exercising its authority under Internal Revenue Code (“Code”) section 1471(f)(4) as added by the Foreign Account Taxpayer Compliance Act (FATCA), enacted in 2010 as part of the Hiring Incentives to Restore Employment (HIRE) Act, to exempt payments beneficially owned by certain foreign retirement plans from withholding under section 1471(a) because such plans pose a low risk of tax evasion as described in section 1471(f)(4).


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