John A. Francisco - Page 9




                                        - 9 -                                         
               The Tax Implementation Agreement Between the United States             
          and American Samoa was executed for the United States by the                
          Assistant Secretary for Tax Policy, effective January 1, 1988.              
          See Tax Implementation Agreement Between the United States of               
          America and American Samoa, 1988-1 C.B. 408.  Adoption of that              
          agreement satisfied the sole precondition to availability of the            
          revised section 931(a) exclusion for residents of American Samoa.           
          See 1986 TRA sec. 1277(b), 100 Stat. 2600.                                  








               7(...continued)                                                        
               such possession with respect to--                                      
                         (1) the elimination of double taxation                       
                    involving taxation by such possession and                         
                    taxation by the United States,                                    
                         (2) the establishment of rules under                         
                    which the evasion or avoidance of United                          
                    States income tax shall not be permitted or                       
                    facilitated by such possession,                                   
                         (3) the exchange of information between                      
                    such possession and the United States for                         
                    purposes of tax administration, and                               
                         (4) the resolution of other problems                         
                    arising in connection with the administration                     
                    of the tax laws of such possession or the                         
                    United States.                                                    
               Any such implementing agreement shall be executed on                   
               behalf of the United States by the Secretary of the                    
               Treasury after consultation with the Secretary of the                  
               Interior.                                                              




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