- 23 - 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 thosePage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011