- 24 - 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 overallPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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