SECTION 5. REQUEST FOR

COMMENTS AND CONTACT INFORMATION

The Treasury Department and the IRS request comments on all aspects of this notice, including whether the rules described in section 3 of this notice should apply to transactions other than covered inbound transactions and whether additional limitations should apply in those cases.

Comments should be submitted by February 26, 2024. Comments may be submitted electronically via the Federal eRulemaking Portal at www.regulations. gov (type IRS-2024-16 in the search field on the regulations.gov homepage to find

this notice and submit comments). Alternatively, comments may be submitted by mail to: Internal Revenue Service, CC:PA:LPD:PR (Notice 2024-16), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. The Treasury Department and the IRS will publish for public availability any comment submitted electronically or on paper to its public docket.

The principal authors of this notice are Karen Li and Brady Plastaras of the Office of Associate Chief Counsel (International). For further information regarding this notice, contact Ms. Li or Mr. Plastaras at (202) 317-6937 (not a toll-free number).

Electronic Filing Administrative Exemptions, Waivers, And Rejections; Obsoleting Notice 2010- 13 and Modifying Notice 2023-60