Zhang v. United States

MEMORANDUM OPINION AND ORDER

CHRISTINE O.C. MILLER, Judge.

This case of first impression is before the court, after argument on defendant’s motion for judgment on the pleadings, involves excise taxes imposed under a compact and implementing legislation formalizing the relationship of the United States Commonwealth of the Northern Mariana Islands (the “CNMI”) and the United States. The issue to be decided is whether nonresident aliens working in the CNMI and a corporate employer owe taxes under the Federal Insurance Contribution Act, 26 U.S.C. (I.R.C.) §§ 3101, 3111 (2006) (“FICA”), for work…