- 13 - derived from sources within possessions of the United States, except for Puerto Rico, the U.S. Virgin Islands, or Guam, if certain conditions were satisfied. Hereinafter, we refer to section 931 before its amendment by TRA 1986 section 1272(a) as old section 931. Old section 931 did not define the term “possession of the United States”. However, regulations promulgated under old section 931 provide, in pertinent part: 9(...continued) the conditions of both paragraph (1) and paragraph (2) are satisfied: (1) 3-year period.--If 80 percent or more of the gross income of such citizen (computed without the benefit of this section) for the 3-year period immediately preceding the close of the taxable year (or for such part of such period immediately preceding the close of such taxable year as may be applicable) was derived from sources within a possession of the United States; and (2) Trade or business.--If 50 percent or more of his gross income (computed without the benefit of this section) for such period or such part thereof was derived from the active conduct of a trade or business within a possession of the United States either on his own account or as an employee or agent of another. (b) Amounts Received in United States.-- Notwithstanding subsection (a), there shall be included in gross income all amounts received by such citizens * * * within the United States, whether derived from sources within or without the United States. (c) Definition.--For purposes of this section, the term “possession of the United States” does not include the Commonwealth of Puerto Rico, the Virgin Islands of the United States, or Guam.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011