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U.S. INCOME TAX TREATIES [i] (MEMORANDUM 2, June 6, 1989)

handle is hein.ali/aliftp0468 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. 2 (June 6, 1989) Subjects Covered: Considerations in the Structuring of Treaty-Shopping Rules Issues Arising in the Treaty Reduction of Source-Based Taxation (Dividends and Branch Profits) Issues Arising in Determining the Profits of an Enterprise Attributable to a Permanent Establishment Issues Involving the Clarification of Income on Which Source-Based Taxation is Reduced or Eliminated Issues Arising in the Treaty Reduction of Source-Based Taxation (Outline) Submitted to the Consultants for consideration at their meeting on June 16 (at 10:00 a.m.) and 17, 1989, at the ALI Conference Center, sixth floor, 4025 Chestnut Street, Philadelphia, Pennsylvania THE EXECUTIVE OFFICE THE AMERICAN LAW INSTITUTE 4025 Chestnut Street Philadelphia, PA 1910tHE AMERCAN LAW INSTITUTE LIBRARy