§931 — Income from sources within Guam, American Samoa, or the Northern Mariana Islands
29 cases·4 followed·8 distinguished·1 criticized·16 cited—14% support
Statute Text — 26 U.S.C. §931
In the case of an individual who is a bona fide resident of a specified possession during the entire taxable year, gross income shall not include—
income derived from sources within any specified possession, and
income effectively connected with the conduct of a trade or business by such individual within any specified possession.
An individual shall not be allowed—
as a deduction from gross income any deductions (other than the deduction under section 151, relating to personal exemptions), or
any credit,
properly allocable or chargeable against amounts excluded from gross income under this section.
For purposes of this section, the term “specified possession” means Guam, American Samoa, and the Northern Mariana Islands.
Amounts paid for services performed as an employee of the United States (or any agency thereof) shall be treated as not described in paragraph (1) or (2) of subsection (a).
Treasury Regulations
- Treas. Reg. §Treas. Reg. §1.931-1 Exclusion of certain income from sources within Guam, American Samoa, or the Northern Mariana Islands
- Treas. Reg. §Treas. Reg. §1.931-1(a) General rule.
- Treas. Reg. §Treas. Reg. §1.931-1(b) Deductions and credits.
- Treas. Reg. §Treas. Reg. §1.931-1(c) Definitions.
- Treas. Reg. §Treas. Reg. §1.931-1(d) Effective/applicability date.
29 Citing Cases
Nothing in the cases cited in the dissenting opinion suggests that section 931(a) does not apply until regulations are issued under section 931(d)(2).
Respondent subsequently determined that, pursuant to section 931,1 petitioners were not entitled to exclude any portion of Mr .
The sole issue for decision is whether petitioner may exclude from gross income under either section 931 or section 911 compensation he earned for personal services he performed in 1997 - 2 - on Johnston Island, a U.S.
On timely filed 1995, 1996, and 1997 returns, petitioner, relying on section 931, excluded wage income relating to his employment with De Silva.
ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 12010-99, 12348-99, Filed August 28, 2001. 14496-99. During the years in issue, Ps lived and worked on Johnston Island, a U.S. insular possession. Ps claim that, under sec. 931, I.R.C., they can exclude from gross income the compensation they received for services they performed on that island. Held: Ps may not exclude from their gross income under sec. 931, I.R.C., the compensation they earned on Johnston Island b
ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 12010-99, 12348-99, Filed August 28, 2001. 14496-99. During the years in issue, Ps lived and worked on Johnston Island, a U.S. insular possession. Ps claim that, under sec. 931, I.R.C., they can exclude from gross income the compensation they received for services they performed on that island. Held: Ps may not exclude from their gross income under sec. 931, I.R.C., the compensation they earned on Johnston Island b
Johnston Island is not a "specified possession" for- purposes of new section 931, so income earned on the Island is not subject to exclusion.
Citizens of the United States and domestic corporations deriving income from sources within a possession of the United States.--(a) Definitions.--(1) As used in section 931 and this section, the term “possession of the United States” includes * * * Johnston Island * * *.
- 2 - The issues for decision are: (1) Are the wages that petitioner received during 1998 while he was residing and working in Johnston Island excludable from petitioner’s gross income for that year under section 931 or section 911?
317, 323-324 (2002) ("Section 931(d)(2) * * * is silent as to whether those regulations may be issued under section 931 or another section ofthe Code, such as sections governing the determination ofsources ofincome (sections 861-865).
rpose and history of the statute in accordance with our analyses in G.D. Searle & Co. v. Commissioner, 88 T.C. 252, 350-351 (1987), and Coca-Cola Co. & Subs. v. Commissioner, 106 T.C. 1, 21 (1996). From section 262 of the Revenue Act of 1921 through section 931, I.R.C. 1954, a qualifying domestic corporation was exempt from Federal income taxes on certain 9(...continued) nonemotive, it is presumed that the author’s language has been used, not for its artistic or emotional effect, but for its abi
rpose and history of the statute in accordance with our analyses in G.D. Searle & Co. v. Commissioner, 88 T.C. 252, 350-351 (1987), and Coca-Cola Co. & Subs. v. Commissioner, 106 T.C. 1, 21 (1996). From section 262 of the Revenue Act of 1921 through section 931, I.R.C. 1954, a qualifying domestic corporation was exempt from Federal income taxes on certain 9(...continued) nonemotive, it is presumed that the author’s language has been used, not for its artistic or emotional effect, but for its abi
rpose and history of the statute in accordance with our analyses in G.D. Searle & Co. v. Commissioner, 88 T.C. 252, 350-351 (1987), and Coca-Cola Co. & Subs. v. Commissioner, 106 T.C. 1, 21 (1996). From section 262 of the Revenue Act of 1921 through section 931, I.R.C. 1954, a qualifying domestic corporation was exempt from Federal income taxes on certain foreign-source income. In the Tax Reform Act of 1976, the Congress eliminated the exemption and in its place enacted the credit mechanism of s
The requirements for exemption from tax as a possession corporation were generally carried forward into section 931 of the Internal Revenue Code of 1954.
The requirements for exemption from tax as a possession corporation were generally carried forward into section 931 of the Internal Revenue Code of 1954.
The requirements for exemption from tax as a possessions corporation were carried forward without material change into section 931 of the Internal Revenue Code of 1954.
The requirements for exemption from tax as a possessions corporation were carried forward without material change into section 931 of the Internal Revenue Code of 1954.