Goldman Sachs High Yield Instl (GSHIX) N-14 Registration statement for investment companies business combination

	One International Place, 40th Floor 100 Oliver Street Boston, MA 02110-2605 +1 617 728 7100 Main +1 617 426 6567 Fax www.dechert.com
	JESSICA HOWELL jessica.howell@dechert.com +1 617 728 7133 Direct +1 617 426 6567 Fax

November 17, 2015

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: Goldman Sachs Trust

Preliminary Registration Statement on Form N-14

Ladies and Gentlemen:

Attached for filing via the EDGAR system is a preliminary Registration Statement on Form N-14 under the Securities Act of 1933, as amended (“1933 Act”), for Goldman Sachs Trust (“Registrant”). This preliminary N-14 is being filed in connection with the reorganization of the Goldman Sachs International Small Cap Fund (“Acquired Fund”), a series of the Registrant, with and into the Goldman Sachs International Small Cap Insights Fund (“Surviving Fund”), another series of the Registrant, in exchange for shares of the Surviving Fund and the assumption by the Surviving Fund of all of the liabilities of the Acquired Fund.

No fee is required in connection with this filing. Please direct any questions concerning the filing to the undersigned at 617.728.7133.

Sincerely,

/s/ Jessica Howell

Jessica Howell