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INTL. ASPECTS OF U.S. INCOME TAXATION i (MEMORANDUM 4, August 26, 1983)

handle is hein.ali/aliftp0461 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 UNITED STATES INCOME TAXATION
Memorandum No. 4
Subject Covered:
Taxation of United States Shareholders of
Foreign Corporations
Submitted to the Consultants for consideration at their meeting on
September 14 (at 10:00 a.m.) and 15, 1983, at the Hyatt Regency, Cambridge, Massachusetts

August 26, 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As an unpublished document intended for internal use, this draft should not be generally circulated or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.