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added.) As we read TRA 1986 section 1277, the amendments to old
section 931 made by TRA 1986 section 1272(a) are not provisional
in their application to petitioners. Congress specifically
provided in TRA 1986 section 1272(a) that section 931 is amended
for tax years beginning after December 31, 1986. In TRA 1986
section 1277(b), Congress makes the application of those
amendments conditional on the existence of the required
implementation agreement between the United States and the
specified possession, but only as to Guam, American Samoa, and
the CNMI, and the residents and corporations thereof. Thus, TRA
1986 section 1277(b) does not apply for bona fide residents of
the other U.S. possessions. As for those residents, the general
effective date of TRA 1986 section 1277(a) controls. As a
result, income earned in any possession other than Guam, American
Samoa, and the CNMI is not eligible for the exclusion provided
under section 931 as amended by TRA 1986 section 1272(a) for tax
years beginning after December 31, 1986. We note further that
nothing in the legislative history supports petitioners’ argument
that Congress intended to keep old section 931 in force as to the
other possessions should one or more of the specified possessions
not implement a tax agreement with the United States. E.g., S.
Rept. 99-313, supra at 484-485, 1986-3 C.B. (Vol. 3) at 484-485.
Petitioners’ reliance on section 1.931-1, Income Tax Regs.,
is misplaced. The regulatory language on which petitioners rely
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