Schnitzer v. State Tax Commission

Edward H. Howell, Judge.

Plaintiff, a resident of Oregon and a shareholder in a corporation organized and doing business in the territory of Guam, paid certain income taxes to the territorial government. Plaintiff claims she is entitled to a credit against her Oregon income taxes for the amounts paid to Guam. ORS 316.475 allows a credit to residents of the state for income taxes “imposed by and paid to another state or country.”

The sole issue is whether Guam is “another state or country” within the meaning of the statute.

Guam, according to 48 USCA § 1421(a), is “an unincorporated territory of…