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Published online by Cambridge University Press: 27 February 2017
* [ Reproduced from the U.S. Federal Register, Vol. 55 No. 118 (June 19, 1991), pp. 28056-75, with corrections incorporated from Vol. 56, No. 164 (August 23, 1991), p. 11792. The Introductory Note was prepared for International Legal Materials by Kenneth Klein, Cadwalader, Wickersham&Taft, and I.L.M. Corresponding Editor for International Taxation.]