Joseph D. Specking, et al. - Page 22




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          the CNMI, under certain conditions, the right to enact their own            
          tax laws, independent of the Code, with respect to income (1)               
          from sources within, or effectively connected with the conduct of           
          a trade or business within, the possession, or (2) received or              
          accrued by a resident of the possession.  TRA 1986 sec. 1271(a).            
          TRA 1986 section 1271(b) makes that grant of authority applicable           
          to Guam, American Samoa, or the CNMI provisional on the existence           
          of an implementing agreement “between the United States and such            
          possession”.  (Emphasis added.)                                             
               TRA 1986 section 1272 amends old section 931 (as well as               
          other Code provisions not pertinent here).  Specifically, TRA               
          1986 section 1272(a) provides in pertinent part:  “In General.--            
          Section 931 (relating to income from sources within possessions             
          of the United States) is amended to read as follows:  ‘SEC. 931.            
          INCOME FROM SOURCES WITHIN GUAM, AMERICAN SAMOA, OR THE NORTHERN            
          MARIANA ISLANDS.’”  See supra p. 14.                                        
               TRA 1986 sections 1271 and 1272 do not specifically address            
          the other U.S. possessions.  Nonetheless, the language of the               
          statute, taken in context, indicates that Congress intended to              
          provide an exclusion from gross income under section 931 as                 
          amended by TRA 1986 section 1272(a) only for bona fide residents            
          of Guam, American Samoa, and the CNMI, and only if the specified            
          possession has an implementing agreement in force with the United           
          States.  Had Congress intended to retain the benefits of section            






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