§1642

§ 1642 (providing that taxes shall be covered into the USVI and “shall be available for expenditure as the [USVI] Legislature . . . may provide”). To get these taxes to the USVI, the VIBIR sends the IRS a cover-over request that typically includes copies of the taxpayer’s USVI return (or parts thereof). See Hulett, 150 T.C. at 65–66. Mr. Tanner too

U.S. citizens or residents (other than those who are bona fide residents ofthe Virgin Islands) who have income derived from sources within the Virgin Islands or effectively connected to a Virgin Islands trade or business for a 7Sec. 932(c) is not included in the mirror code and is not an element ofthe Virgin Islands territorial ta

U.S. citizens or residents (other than those who are bona fide residents ofthe Virgin Islands) who have income derived from sources within the Virgin Islands or effectively connected to a Virgin Islands trade or business for a 7Sec. 932(c) is not included in the mirror code and is not an element ofthe Virgin Islands territorial ta

Thus, any tax collected in this matter by the United States would be covered over to the Government ofthe Virgin Islands." Sec. 932(c) is not included in the mirror code and is not an element ofthe Virgin Islands territorial tax system. See S. Rept. No. 100-445, at 314-315 (1988), 1988 U.S.C.C.A.N. 4515, 4825-4826. 13At the Octobe

Thus, any tax collected in this matter by the United States would be covered over to the Government of the Virgin Islands. III. Federal Tax Filing Requirements As a U.S. citizen, petitioner is subject to Federal reporting requirements and taxation on his worldwide income as set forth in the Code. See, e.g., Cook v. Tait, 265 U.S.

1642 (1994), was required to pay tax to the United States on its worldwide income. Summary judgment may be granted if the pleadings and other materials demonstrate that no genuine issue exists as to any material fact and that a decision may be entered as a matter of law. See Rule 121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992