ach to determining possession ECI similar to that employed in allocating income between the United States and its foreign treaty partners under the U.S. Model Income Tax Treaty ("Model Treaty"). The Government further proposes that Treasury modify its regulations under Section 937(b)(2) to narrow the U.S. income limitation

Aspects: International Bar Association. Tax Aspects of Cross-Border Transactions in Latin American Markets. Sao Paulo. Brazil. May 2007 Panelist. "U.S. Model Income Tax Treaty: May Meeting. American Bar Association Section of Taxation. Washington. D.C.. May 2007 Panelist. "Alternative Structures for Foreign Investment in