Stanley C. Ruchelman was a substantive contributor to the A.B.A. Section of Taxation, Committee on U.S. Activities of Foreigners and Tax Treaties (“U.S.A.F.T.T.”) Comments on Notice 2013-78, submitted on March 10, 2013. The comments addressed procedures set forth in I.R.S. Notice 2013-78 regarding requests for assistance of the Competent Authority (“C.A.”) under U.S. tax treaties and provided suggestions to encourage participation and clarify procedures for U.S. taxpayers.