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INTL. ASPECTS OF U.S. INCOME TAXATION i (TAX ADVISORY GROUP DRAFT 13, October 26, 1983)

handle is hein.ali/aliftp0425 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
Tax Advisory Group Draft No. 13
Subjects Covered:
INTERNATIONAL ASPECTS OF UNITED STATES INCOME TAXATION
United States Taxation of Foreign Persons
V. Recommended Rule for the Source of Effectively Connected Income
VI. General Considerations Concerning Tax Base and Rate of Tax
VII. Treatment of Different Kinds of Income
VIII. Additional Issues in the Structure of Net Basis Taxation
IX. Branch Remittance Tax
X. Issues in the Imposition of Gross Basis Tax
XI. Penalty Taxes
Submitted to the Tax Advisory Group for consideration at its meeting on November 10 (at 10:00 a.m.),
11 and 12, 1983, at the Vista International Hotel, Washington, D.C.
October 26, 1983
THE ExEcuTIV. OFFICE
THE AMEtucAN LAw INSTrTUTE
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As an unpublished document intended for internal use, this draft should not be generally circulated or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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