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U.S. INCOME TAX TREATIES [i] (MEMORANDUM 6, September 19, 1990)

handle is hein.ali/aliftp0472 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. 6
(September 19, 1990)

Subjects Covered:
Part One:    The Purpose of Income Tax Treaties
and Their Legal, Consequences
Part Two:    Issues Arising In the Treaty Reduction
of Source-Based Taxation
Part Three:  Issues Relating to Residence Country Taxation
Part Four:   Non-Discrimination

Submitted to the Consultants for consideration at their meeting on October 5
(at 10:00 a.m,) and 6, 1990, at the Great Hall In the D'Agostino Conference Center,
New York University School of Law, 40 Washington Square South, New York, New York

MIE EXECUTIVE OFFICE
'MTE AMERICAN LAW INSTITUTE
4025 Chestnut Street
Philadelphia, PA 19104