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U.S. INCOME TAX TREATIES [i] (MEMORANDUM 4, March 8, 1990)

handle is hein.ali/aliftp0470 and id is 1 raw text is: This document, as of the date it was printed, had not been considered by the Council or membership of The American Law Institute, and therefore does not represent the position of the Institute on any of the issues with which it deals. The American Law Institute FEDERAL INCOME TAX PROJECT UNITED STATES INCOME TAX TREATIES Memorandum No. 4 (March 8, 1990) Subjects Covered: Part One: The Purpose of Income Tax Treaties and Their Legal Consequences Introductory Discussion The Cherry-Picking Problem Part Two: Issues Relating to Residence Country Taxation The Savings Clause Relief from Double Taxation Part Four: Other Treaty Constraints on or Modifications of Domestic Law The Non-Discrimination Article Submitted to the Consultants for consideration at their meeting on March 23 (at 10:00 a.m.) and 24, 1990, at the Great Hall in the D'Agostino Conference Center, New York University School of Law, 40 Washington Square South, New York, New York The Executive Office The American Law Institute 4025 Chestnut Street Philadelphia, Pennsylvania 19104

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