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INTL. ASPECTS OF U.S. INCOME TAXATION [i] (COUNCIL DRAFT 11, November 24, 1982)

handle is hein.ali/aliftp0367 and id is 1 raw text is: THIS DRAFT IS PRIVATE AND CONFIDENTIAL PUBLIC DISCLOSURE IS PROHIBITED* (Not to be sold, offered for sale, or otherwise published) The American Law Institute FEDERAL INCOME TAX PROJECT INTERNATIONAL ASPECTS OF U.S. INCOME TAXATION Council Draft No. 11 Subjects Covered: Introduction United States Taxation of Foreign Persons I. General Considerations Concerning the Income Taxation of Foreign Persons II. Basic Approach to the Formulation of Taxing Jurisdiction Based on Source III. General Features of Existing Law IV. Recommended Rules for Determining the Source of Income Submitted to the meeting of the Council of The American Law Institute on December 8 (at 10:00 a.m.), 9, 10, 11, 1982 at the Association of the Bar of the City of New York, 42 West 44th Street, New York City. This Draft is scheduled for discussion on Friday, December 10, at 9:30 a.m. November 24, 1982 The Executive Office THE AMERICAN LAW INSTITUTE 4025 Chestnut Street Philadelphia, PA 19104 *This Is a preliminary draft submitted on a private and confidential basis to a limited group for the sole purpose of study and criticism. It has not been promulgated or approved by the Council or the members of The American Law Institute. As an unpublished document intended for internal use, this draft should not be generally circulated or distributed, nor should it be quoted from or cited or its substance disclosed in any public address or writing.

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