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April 4, 2011: TD Bank Financial Group


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Peter van Dijk of TD Bank Financial Group (“TD), supplementing prior comments, has expressed concerns that preliminary guidance (Notice 2010-60) on the FATCA withholding and reporting provisions could lead to significant conflict-of-law issues and that FATCA's cost burdens are disproportionate to its expected benefits.

A copy of the "TD" letter, as originally published by Tax Analysts, is attached.

Contact FATCA Leader  for further information.

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