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931 for residents of the other U.S. possessions it would not have
used the restrictive language found in those provisions, as well
as in TRA 1986 section 1277. Compare TRA 1986 sec. 1271(a)
(“such possession”), sec. 1271(b) (“such possession”), sec.
1272(a) (“specified possession”), and sec. 1277(b) (“such
possession”), with, e.g., TRA 1986 sec. 201(a), 100 Stat. 2121,
2127, 2131, amending Code sec. 168 (Code sec. 168(g)(6)(B): “For
purposes of this subparagraph, the term ‘United States’ includes
the Commonwealth of Puerto Rico and the possessions of the United
States” (emphasis added), and Code sec. 168(h)(4)(A)(ii): “For
purposes of clause (i), the United States, each State, and each
possession of the United States” (emphasis added)); TRA 1986 sec.
252, 100 Stat. 2189, 2199, adding Code sec. 42 (Code sec.
42(h)(7)(B): “The term ‘State’ includes a possession of the
United States” (emphasis added)); TRA 1986 sec. 1301(a), 100
Stat. 2602, 2603, amending Code sec. 103 (Code sec. 103(c)(2):
“The term ‘State’ includes the District of Columbia and any
possession of the United States” (emphasis added)).
We find support for our understanding of the statute in its
legislative history. E.g., S. Rept. 99-313, at 477-482 (1986),
1986-3 C.B. (Vol. 3) 1, 477-482. Nowhere in that legislative
history does Congress indicate an intention to continue to extend
the benefits of section 931 to bona fide residents of any of the
other U.S. possessions or to income from sources within those
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