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2. Grant to Guam, American Samoa, and the CNMI of Control
Over Their Tax Systems
Guam, American Samoa, and the CNMI had a mirror or modified
mirror system of taxation for many years before 1986. Under that
system, American Samoa, in 1963, adopted substantially all of the
Internal Revenue Code of 1954, 11 A.S.C.A. sec. 11.0501,6 but
American Samoans paid the tax to American Samoa, not the United
States.
5(...continued)
any specified possession, and
(2) income effectively connected with
the conduct of a trade or business by such
individual within any specified possession.
* * * * * * *
(d) Special Rules.--For purposes of this section--
* * * * * * *
(2) Determination of source, etc.--The
determination as to whether income is
described in paragraph (1) or (2) of
subsection (a) shall be made under
regulations prescribed by the Secretary.
(3) Determination of residency.--For
purposes of this section and section 876, the
determination of whether an individual is a
bona fide resident of Guam, American Samoa,
or the Northern Mariana Islands shall be made
under regulations prescribed by the
Secretary.
6 See Boral Gas, Inc. v. Iaulualo, No. CA 87-1 (Am. Samoa
Oct. 3, 2002).
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