llowing items: (i) In 2005, a favorable one-time tax benefit of $77 million related to the repatriation of foreign earnings under the provisions of the American Jobs Creation Act and pretax interest income of $40 million related to an Internal Revenue Serivice tax settlement. See additional discussion in Note 10 to the Conso

effectively connected income" under the provisions of Section 937(a) and (b) of the Internal Revenue Code of 1986, as amended ("Code"), as added by the American Jobs Creation Act of 2004 ("Jobs Act") and as it applies to taxpayers in the U.S. Virgin Islands ("USVI" or "Territory"). The scope and content of those provisions ar

ng built-in loss property to a partnership from transferring the loss to another person through the subsequent transfer of his partnership interest, the American Jobs Creation Act of 2004 amended IRC section 704(c) of the Code by adding IRC section 704(c)(1)(C), effective for contributions of property to a partnership after O

come is effectively connected with the conduct of a trade or business within a U.S. possession. Section 937 was added to the Code by section 908 of the American Jobs Creation Act (2004 Act). The temporary regulations also provide updated guidance under sections 876, 881, 884, 931, 932, 933, 934, 935, 957, and 6688 of the Cod