Rev. Rul. 82-151

ISSUE

Are the U.S. Virgin Islands, Guam, and American Samoa part of the "North American area" for purposes of section 274(h) of the Internal Revenue Code, relating to attendance at conventions?

LAW

Section 274(h) of the Code prohibits a deduction under section 162 or 212 for expenses allocable to any individual who attends a convention, seminar, or similar meeting hold outside the North American area, unless the taxpayer establishes that the meeting is directly related to the active conduct of the taxpayer's trade or business or investment activity and it is as reasonable for the meeting to have been held outside the North American area as within it.

Section 274(h)(3)(A) of the Code defines "North American area" as the United States, its possessions, and the Trust Territory of the Pacific Islands, and Canada and Mexico.

HOLDING

The definition of "North American area" in section 274(h)(3)(A) includes the U.S. Virgin Islands, Guam, and American Samoa.