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U.S. INCOME TAX TREATIES [i] (MEMORANDUM 2, June 6, 1989)

handle is hein.ali/aliftp0468 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. 2
(June 6, 1989)

Subjects Covered:
Considerations in the Structuring of Treaty-Shopping Rules
Issues Arising in the Treaty Reduction of Source-Based Taxation
(Dividends and Branch Profits)
Issues Arising in Determining the Profits of an Enterprise
Attributable to a Permanent Establishment
Issues Involving the Clarification of Income on Which
Source-Based Taxation is Reduced or Eliminated
Issues Arising in the Treaty Reduction of Source-Based Taxation
(Outline)
Submitted to the Consultants for consideration at their meeting on
June 16 (at 10:00 a.m.) and 17, 1989, at
the ALI Conference Center, sixth floor,
4025 Chestnut Street, Philadelphia, Pennsylvania
THE EXECUTIVE OFFICE
THE AMERICAN LAW INSTITUTE
4025 Chestnut Street
Philadelphia, PA 1910tHE AMERCAN LAW INSTITUTE
LIBRARy

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