^{page 559 note 1} Dept. of State File No. P89 0049-2112.

^{page 560 note 1} Dept. of State File No. P89 0049-0148.

^{page 560 note 2} Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, and Related Protocol and Exchange of Notes, July 11,1988, United States-Indonesia, S. TREATY DOC. No. 22, 100th Cong., 2d Sess. (1988). Under Article 3(1)(a), for purposes of the Convention only, unless otherwise required by the context, the term “ ‘Indonesia’ comprises the territory of the Republic of Indonesia and the adjacent seas which [sic] the Republic of Indonesia has sovereignty, sovereign rights or jurisdictions in accordance with the provisions of the 1982 United Nations Convention on the Law of the Sea.” Id. at 1.

^{page 561 note 3} Id. at 21–22.

^{page 561 note 1} On Jan. 30, 1989, the Acting U.S. Trade Representative, Alan V. Holmer, issued guidelines for U.S. implementation of the Memorandum of Agreement, to be effective upon its entry into force. 54 Fed. Reg. 4931 (1989).

^{page 561 note 2} For the texts of the three agreements, see 28 ILM 596 (1989). The agreements entered into force on Mar. 16, 1989. The licenses were issued and the Government of the People’s Republic of China was notified on the same day.

^{page 562 note 1} Dept. of State, American Foreign Policy: Current Documents, 1987, at 422 (1988).

^{page 562 note 2} Dept. of State Staff Secretariat Log No. 8714543; Dept. of State File No. P89 0048-1821, reprinted in 26 ILM 1427 (1987).

^{page 563 note 3} Ministry of Foreign Affairs Legal Bureau, Note No. 398, May 21, 1987, Dept. of State File No. P89 0048-1820, reprinted in 26 ILM at 1428.

^{page 563 note 4} Dept. of State File No. P89 0048-1823.

^{page 563 note 5} Dept. of State File No. P89 0048-1826.

^{page 564 note 6} Dept. of State File No. P89 0048-1818, reprinted in 28 ILM at 645.