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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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