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U.S. INCOME TAX TREATIES [i] (MEMORANDUM 1, March 8, 1989)

handle is hein.ali/aliftp0467 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. 1
(March 8, 1989)

Subjects Covered:
Considerations in the Structuring of Theaty-Shopping Rules
Issues Arising in the Treaty Reduction of Source-Based Thxation

Submitted to the Consultants for consideration at their meeting on
March 17 (at 10:00 a.m.) and 18, 1989, at
the ALI Conference Center, fourth floor,
4025 Chestnut Street, Philadelphia, Pennsylvania

THE ExEcutnvE OFFicE
THE AMElCAN LAW INSTITUTE
4025 Chestnut Street
Philadelphia, PA 19104,