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statutory scheme, shows that the amendments to old section 931
became effective as to petitioners for tax years beginning after
December 31, 1986.
TRA 1986 section 1277(a) provides that the amendments made
by TRA 1986 subtitle G in general become effective for taxable
years beginning after December 31, 1986, unless otherwise
provided in TRA 1986 section 1277. Thus, unless an exception to
that general effective date is provided by another subsection of
TRA 1986 section 1277, the amendments to old section 931 became
effective as to petitioners for tax years beginning in 1987. We
focus below on subsection (b) of TRA 1986 section 1277 because
the other subsections are not relevant to the issue involved in
this case.17
TRA 1986 section 1277(b) provides that the amendments made
by subtitle G of title XII “apply with respect to Guam, American
Samoa, or the Northern Mariana Islands” and to residents thereof
and corporations created or organized therein “only if (and so
long as) an implementing agreement under section 1271 is in
effect between the United States and such possession.” (Emphasis
17TRA 1986 sec. 1277(c) relates to the Virgin Islands; TRA
1986 sec. 1277(d) mandates reports from the Secretary relating to
the implementation agreements described in TRA 1986 sec. 1277(b)
and (c), should certain conditions arise; and TRA 1986 sec.
1277(e) provides a special rule for U.S. citizens who become
residents of Guam, American Samoa, or the CNMI. TRA 1986, 100
Stat. 2601-2602.
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