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Sidley Austin LLP 787 Seventh Avenue New York, NY 10019 +1 212 839 5300 +1 212 839 5599 Fax |
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+1 212 839 8679 MKUTNER@sidley.com | ||
| AMERICA • ASIA PACIFIC • EUROPE |
June 22, 2020
Kenneth Ellington
Staff Accountant
U.S. Securities and Exchange Commission
Division of Investment Management, Disclosure Review and Accounting Office
100 F. Street, N.E.
Washington, DC 20549
| Re: | First Eagle Variable Funds (the “Fund”) | |
| File Nos.: 033-96668 and 811-09092 |
Dear Mr. Ellington:
Thank you for your comments to the Fund’s response letter dated June 5, 2020, filed with the Securities and Exchange Commission (the “Commission”) on June 5, 2020, regarding the Certified Shareholder Report on Form N-CSR of the Fund, filed with the Commission on March 5, 2020. This letter responds to your comments, which you provided to us by telephone on June 8, 2020.
Capitalized terms used, but not otherwise defined, have the meaning ascribed to them in the Report.
| 1. | COMMENT: You asked for certain supplemental information about the Fund’s foreign tax reclaims receivables that remain outstanding. | |
| RESPONSE: A tabular response including the countries for which foreign tax reclaim receivables remain outstanding is included below: |
| Fund | Country |
| First Eagle Overseas Variable Fund | Belgium |
| Denmark | |
| France | |
| Germany | |
| Ireland | |
| Poland | |
| Switzerland |
****
Sidley Austin (NY) LLP is a Delaware limited liability partnership doing business as Sidley Austin LLP and practicing in affiliation with other Sidley Austin partnerships.
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Should you have any follow-up questions concerning this letter, please do not hesitate to contact me at (212) 839-8679.
| Sincerely, | |
| /s/ Matthew Kutner | |
| Matthew J. Kutner, Esquire (as Attorney for the Funds) |