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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As an unpublished document intended for internal use, this draft should not be generally circulated or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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