Joseph D. Specking, et al. - Page 23




                                       - 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 those               






Page:  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