the District of Columbia voting representation, though none were successful. (7) In 1898, Puerto Rico was acquired by the United States and currently has a Resident Commissioner with limited voting rights. Section 933 of the Internal Revenue Code of 1986 exempts bona fide citizens who are residents of Puerto Rico for the entire taxable year from Federal taxes on income earned in Puerto Rico. (8) On March 31, 1917, the United States took possession of the Virgin Islands and in 1927, the territory’s residents were granted citizenship. Under section 932 of the Internal Revenue Code of 1986, individuals who are bona fide residents of the United States Virgin Islands during the entire taxable year, and who fully pay all income tax liabilities to the United States Virgin Islands, are not subject to Federal income taxes on their income. (9) Guam was established as a territory of the United States after the passage of the Guam Organic Act of 1950. Under the provisions of section 935 of the Internal Revenue Code of 1986, residents of Guam are required to file tax returns with Guam, but not with the United States Federal Government and therefore the residents do not have to pay United States Federal income taxes. (10) The Commonwealth of the Northern Mariana Islands was established in 1975 after residents decided not to pursue independence, but instead they opted to enter into territory negotiations. The tax treatment of the Northern Mariana Islands is similar to the structure of Guam in that bona fide residents are not required to pay Federal income taxes. (11) American Samoa, which is technically considered unorganized because no Organic Acts have been passed by Congress, is governed by section 931 of the Internal Revenue Code of 1986. Under this section, bona fide year-round residents are exempt from Federal taxes on income they earn in Samoa, Guam, and Northern Mariana Islands, but are subject to Federal taxes on income earned elsewhere. (12) In keeping with the early history and democratic traditions of the United