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INTL. ASPECTS OF U.S. INCOME TAXATION i (MEMORANDUM 7, October 5, 1984)

handle is hein.ali/aliftp0464 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. 7. (October 5, 1984) Subjects Covered: Foreign Tax Credit: General Principles Definition of U.S. Persons Submitted to the Consultants for consideration at their meeting on October 19 (at 10:00 a.m.) and 20, 1984 at the ALl Conference Center, fourth floor, 4025 Chestnut Street, Philadelphia, Pennsylvania 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 As an unpublished document intended for internal use, this draft should not be generally circulated or distributed, nor should it be quoted from or cited or its substance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.