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�1.931-1. Citizens of the United States and
domestic corporations deriving income from sources
within a possession of the United States.--(a)
Definitions. (1) As used in section 931 and this
section, the term “possession of the United States”
includes American Samoa, Guam, Johnston Island, Midway
Islands, the Panama Canal Zone, Puerto Rico, and Wake
Island. However, the term does not include (i) the
Virgin Islands and (ii), when used with respect to
citizens of the United States, the term does not
include Puerto Rico or, in the case of taxable years
beginning after December 31, 1972, Guam.
(2) As used in section 931 and this section, the
term “United States” includes only the States, the
Territories of Alaska and Hawaii, and the District of
Columbia. [Emphasis added.]
The last amendment to section 1.931-1, Income Tax Regs., was
promulgated in 1975. T.D. 7385, 40 Fed. Reg. 50260 (Oct. 29,
1975).
B. Statutory Language After TRA 1986
TRA 1986 section 1272(a) amended old section 931 to read, in
pertinent part:
SEC. 931. INCOME FROM SOURCES WITHIN GUAM, AMERICAN
SAMOA, OR THE NORTHERN MARIANA ISLANDS.
(a) General Rule.--In the case of an individual
who is a bona fide resident of a specified possession
during the entire taxable year, gross income shall not
include--
(1) income derived from sources within any
specified possession, and
(2) income effectively connected with the
conduct of a trade or business by such individual
within any specified possession.
* * * * * * *
(c) Specified Possession.--For purposes of this
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