86 STAT. ]
PUBLIC LAW 92-606-OCT. 31, 1972
1495
applies for the taxable year shall file his income tax return for the taxable year—
.?5' " (A) with the United States, if he is a resident of the United. States, "^B) with Guam, if he is a resident of Guam, and " (C) if neither subparagraph (A) nor subparagraph (B) applies— "(i) with Guam, if he is a citizen of Guam but not otherwise a citizen of the United States, or "(ii) with the United States, if clause (i) does not ^^^apply. ^' (2) DETERMINATION DATE.—For purposes of this section, determinations of residence and citizenship for the taxable year shall be made as of the close of the taxable year. "(3) SPECIAL RULE FOR JOINT RETURNS.—In the case of a joint return, this subsection shall be applied on the basis of the residence J30l»* and citizenship of the spouse who has the greater adjusted gross income (determined without regard to community property laws) for the taxable year. "(c) EXTENT or INCOME TAX LIABILITY.—In the case of any individual to whom this section applies for the taxable year— "(1) for purposes of so much of this title (other than this section and section 7654) as relates to the taxes imposed by this intra. chapter, the United States shall be treated as including Guam, "(2) for purposes of the Guam territorial income tax, Guam shall De treated as including the United States, and "(3) such individual is hereby relieved of liability for income tax for such year to the jurisdiction (the United States or Guam) other than the jurisdiction with which he is required to file under subsection (b). " (d) SPECIAL RULES FOR ESTIMATED INCOME TAX.—If there is reaQi't -li-Sr- th son to believe that this section will apply to an individual for the taxable year, then—• "(1) he shall file any declaration of estimated income tax (and all amendments thereto) with the jurisdiction with which he would be required to file a return for such year under subsection (b) if his taxable year closed on the date he is required to file such declaration, Qf.i. q ,fiinh "(2) he is hereby relieved of any liability to file a declaration of estimated income tax (and amendments thereto) for such taxable year to the other jurisdiction, and "(3) his liability l o r underpayments of estimated income tax '. ^? ' J f ^ i J **• shall be to the jurisdiction with which he is required to file his return for the taxable year (determined under subsection (b)). " (b) ADMINISTRATION.—Section 7654 of the Internal Revenue Code Stat. 909. of 1954 (relating to payment to Guam and American Samoa of pro- 68Au s e 7654. 26 ceeds of tax on coconut and other vegetable oils) is amended to read as follows: "SEC. 7654. COORDINATION OF UNITED STATES AND GUAM INDIVIDUAL INCOME TAXES. " (a) GENERAL RULE.—The net collections of the income taxes
imposed for each taxable year with respect to any individual to whom this subsection applies for such year shall be divided between the United States and Guam according to the following rules: "(1) net collections attributable to United States source income shall be covered into the Treasury of the United States; "(2) net collections attributable to Guam source income shall be covered into the treasury of Guam; and " (3) all other net collections of such taxes shall be covered into
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