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September 23, 2011: Hogan Lovells US LLP


On September 23, Hogan Lovells submits comments to Notice 2011-34. The comments are a working draft and not exhaustive but include suggestions the IRS and Treasury may find helpful as it considers the “diligent review” standard for reviewing Private Banking and other high value accounts under FATCA.

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

Contact FATCA Leader  for further information.

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