- 3 - the years in issue, petitioner was an "inhabitant" of the USVI within the meaning of section 28(a) of the Revised Organic Act. Through the Naval Appropriations Act, ch. 44, 42 Stat. 122 (1921), Congress made the United States income tax laws applicable to the USVI. See Danbury, Inc. v. Olive, 820 F.2d 618, 620 (3d Cir. 1987); Condor Intl., Inc. v. Commissioner, 98 T.C. 203, 211 (1992), affd. in part and revd. in part on other grounds 78 F.3d 1355 (9th Cir. 1996). The Naval Appropriations Act created a separate territorial income tax which the USVI Government would collect by applying the United States income tax laws with necessary changes where appropriate. See Bizcap, Inc. v. Olive, 892 F.2d 1163, 1165 (3d Cir. 1989); Condor Intl., Inc. v. Commissioner, supra. A "mirror" system of taxation was created by substituting "Virgin Islands" for "United States", in the Internal Revenue Code. See Bizcap, Inc. v. Olive, supra; Condor Intl., Inc. v. Commissioner, supra. To satisfy a USVI tax obligation, a corporation inhabiting the USVI was required to pay the same amount of taxes to the USVI Bureau of Internal Revenue (BIR) as a domestic U.S. corporation would be required to pay to the Internal Revenue Service (IRS) under the same circumstances. See Bizcap, Inc. v. Olive, supra; Condor Intl., Inc. v. Commissioner, supra. The Naval Appropriations Act required some corporations to file two returns. For example, a domestic U.S. corporation doingPage: Previous 1 2 3 4 5 6 7 8 Next
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