Joseph D. Specking, et al. - Page 24




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          other possessions.  The following passage from S. Rept. 99-313 is           
          illustrative:                                                               
                    An individual who is a bona fide resident of Guam,                
               American Samoa, or the CNMI during the entire taxable                  
               year is subject to U.S. taxation in the same manner as                 
               a U.S. resident.  However, in the case of such an                      
               individual, gross income for U.S. tax purposes does not                
               include income derived from sources within any of the                  
               three possessions * * *.  * * *  Thus, even a bona fide                
               resident of Guam, the CNMI, or American Samoa is                       
               required to file a U.S. return and to pay taxes on a                   
               net basis if he receives income from sources outside                   
               the three possessions (i.e., U.S. or foreign source                    
               income).  * * *  [Id. at 480-481, 1986-3 C.B. (Vol. 3)                 
               at 480-481; emphasis added.]                                           
               Our understanding of the statute also comports with                    
          congressional intent of enabling Guam, American Samoa, and the              
          CNMI to enact their own tax laws independent of the Code, subject           
          to certain restrictions, coordinating their tax systems with the            
          U.S. tax system, and preventing those possessions from being used           
          as tax havens.  Id. at 479, 1986-3 C.B. (Vol. 3) at 479.                    
               Petitioners, however, contend that the amendments to old               
          section 931 made by TRA 1986 section 1272(a) are merely “proposed           
          changes” until Guam, American Samoa, and the CNMI enact valid               
          implementing agreements with the United States.  We do not agree.           
               TRA 1986 section 1277, see supra note 11, in part IV of                
          subtitle G, provides effective dates for all of subtitle G.  TRA            
          1986 section 1277 does not specifically address the other U.S.              
          possessions.  However, the language of that provision, taken in             
          context with the other statutory provisions and the overall                 






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