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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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