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U.S. INCOME TAX TREATIES [i] (MEMORANDUM 5, June 6, 1990)

handle is hein.ali/aliftp0471 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. 5
(June 6, 1990)

Subjects Covered:
Part One: The Purpose of Income Tax Treaties and Their
Legal Consequences
Part Two: Issues Relating to Residence Country Taxation
Part Four: Other Treaty Constraints on or Modifications
of Domestic Law
The Non-Discrimination Article
Submitted to the Consultants for consideration at their meeting on
June 15 (at 10:00 a.m.) and 16, 1990, at
the Great Hall in the D'Agostino Conference Center,
New York University School of Law,
40 Washington Square South, New York, New York

The Executive Office
The American Law Institute
4025 Chestnut Street
Philadelphia, Pennsylvania 19104

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