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MEMORANDUM TO COUNCIL [RE SUBCHAPTER C] 1 (November 25, 1986)

handle is hein.ali/aliftp0342 and id is 1 raw text is: THE AMERICAN LAW INSTITUTE OFFICE OF THE DIRECTOR YALE LAW SCHOOL 401 A YALE STATION NEW HAVEN, CT 06520 GEOFFREY C. HAZARD, JR. DIRECTOR (203) 435-8253 Date: November 25, 1986 To: Members of the Council From: Geoffrey C. Hazard, Jr., Director Re: Proposed Tax Projects On-*he recommendation of the Institute's Tax Program Committee I recommend the approval, subject to funding, of A Supplemental Study of Subchapter C. I also attach an outline and schedule for the Study of Income Tax Treaties which the Council approved, subject to funding, in May. 1. Supplemental Study of Subchapter C. The Institute previously did an extensive study of Subchapter C, published in 1982. This study had very significant influence on development of the law governing taxation of corporations. This year the Internal Review Code was comprehensively revised, including revisions that very substantially affected the transactions governed by Subchapter C. It is evident that many complex issues have been generated, not all of which have been resolved. The Treasury Department Is conducting.a study of its own on the.subject, to be reported to

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