- 17 - maintain that such condition precedent to the effective date of TRA 1986 section 1272(a) has not been fulfilled inasmuch as only American Samoa has effectuated a tax implementation agreement with the United States. Tax Implementation Agreement Between the United States of America and American Samoa, 1988-1 C.B. 408.13 Petitioners further assert that there is no evidence that the tax implementation agreement executed by American Samoa and the United States fully satisfies the requirements of TRA 1986 section 1271(b). Hence, petitioners maintain, since the 12(...continued) Islands only if (and so long as) an implementing agreement is in effect between the United States and such possession with respect to-- (1) the elimination of double taxation involving taxation by such possession and taxation by the United States. (2) the establishment of rules under which the evasion or avoidance of United States income tax shall not be permitted or facilitated by such possession. (3) the exchange of information between such possession and the United States for purposes of tax administration, and (4) the resolution of other problems arising in connection with the administration of the tax laws of such possession or the United States. 13Representatives for the Government of American Samoa signed the tax implementation agreement on Dec. 10, 1987, and the representative for the Government of the United States signed it on Jan. 7, 1988. The tax implementation agreement generally became effective as of Jan. 1, 1988. Tax Implementation Agreement Between the United States of America and American Samoa, 1988-1 C.B. 408, 411. Although the United States and Guam entered into a tax implementation agreement, Tax Implementation Agreement Between the United States of America and Guam, 1989-1 C.B. 342, that agreement is not yet effective. Treasury News Release NB-1077 (Dec. 27, 1990).Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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