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We disagree with petitioner; the statutory language,
differences between the House and Senate versions of the 1986
TRA, and differences in the House and Senate committee reports
for the 1986 TRA compel a different reading. The House bill
(section 615(a) of H.R. 3838) provided that ocean activity income
is sourced in the country of residence of the person generating
the income. H. Rept. 99-426, supra at 382, 1986-3 C.B. (Vol. 2)
at 382. In contrast, the Senate bill (section 915(a) of H.R.
3838) provided that ocean-activity income derived by U.S.
persons10 is sourced in the United States and income derived by
persons other than U.S. persons is sourced outside the United
States. S. Rept. 99-313, supra at 358, 1986-3 C.B. (Vol. 3) at
358. The Senate Finance Committee report for the 1986 TRA
included a modified version of the House description which
reflects the change in bill language. The Senate report said in
pertinent part:
all income derived from space or ocean activities is
sourced in the country of residence of the person
generating the income: income derived by United States
persons (as defined in sec. 7701(a)(30)) is U.S. source
income and income derived by persons other than U.S.
persons is sourced outside the United States.
S. Rept. 99-313, supra at 358, 1986-3 C.B. (Vol. 3) at 358.
The conference report included the Senate version of the
10 See supra note 9.
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