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INTL. ASPECTS OF U.S. INCOME TAXATION i (MEMORANDUM 3, March 11, 1983)

handle is hein.ali/aliftp0460 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 Memorandum No. 3 SubjectT Covered: 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 Consultants for consideration at their meeting on March 25 (at 10:00 a.m.), 26, and 27, 1933, at the ALI Conference Center, fourth floor, 4025 Chestnut Street, Philadelphia, Pennsylvania March 11, 1983 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 As an unpublished document intended for Internal use.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.