Commonwealth of the Northern Mariana Islands
MP · territory · 9 cited facts
| Category | Provision | Value | Source |
|---|---|---|---|
| conformity | Capital gains rate (TY2025) | Mirrors federal IRC § 1(h): 0% / 15% / 20% LTCG (12-month hold); ordinary rates on STCG; 48 U.S.C. § 1801 Covenant § 601 Mirror Code | sources (1)48 U.S.C. § 1801, Covenant to Establish a Commonwealth of the CNMI, § 601 (Pub. L. 94-241, 90 Stat. 263 (1976)) · high confidence · as of 2026-06-19 · TY 2025 CNMI Mirror Code: federal income tax laws apply in CNMI as territorial income tax, in the same manner as Guam Section 601. (a) The income tax laws in force in the United States will come into force in the Northern Mariana Islands as a local territorial income tax on the first day of January following the effective date of this Section, in the same manner as those laws are in force in Guam. Note: The CNMI Mirror Code operates via the Guam Mirror Code (48 U.S.C. § 1421i) as the template. IRC references to 'Guam' automatically extend to CNMI per § 601(c): 'References in the Internal Revenue Code to Guam will be deemed also to refer to the Northern Mariana Islands, where not otherwise distinctly expressed or manifestly incompatible with the intent thereof or of this Covenant.' This incorporates the full Subtitle A of the IRC, including IRC § 1(h) (the 0%/15%/20% LTCG rate schedule) and the 12-month holding period under IRC § 1222. Tax is paid to the CNMI government, not the federal treasury. No CNMI-specific modification to capital gains rates found in federal statute. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title48-section1801&num=0&edition=prelim |
| character | Long-term holding period | 12 months (same as federal IRC § 1222); CNMI applies the full federal IRC via Mirror Code (Covenant § 601, 48 U.S.C. § 1801) | sources (1)48 U.S.C. § 1801, Covenant to Establish a Commonwealth of the CNMI, § 601 (Pub. L. 94-241, 90 Stat. 263 (1976)) · high confidence · as of 2026-06-19 · TY 2025 CNMI Mirror Code: federal income tax laws apply in CNMI as territorial income tax, in the same manner as Guam Section 601. (a) The income tax laws in force in the United States will come into force in the Northern Mariana Islands as a local territorial income tax on the first day of January following the effective date of this Section, in the same manner as those laws are in force in Guam. Note: The CNMI Mirror Code operates via the Guam Mirror Code (48 U.S.C. § 1421i) as the template. IRC references to 'Guam' automatically extend to CNMI per § 601(c): 'References in the Internal Revenue Code to Guam will be deemed also to refer to the Northern Mariana Islands, where not otherwise distinctly expressed or manifestly incompatible with the intent thereof or of this Covenant.' This incorporates the full Subtitle A of the IRC, including IRC § 1(h) (the 0%/15%/20% LTCG rate schedule) and the 12-month holding period under IRC § 1222. Tax is paid to the CNMI government, not the federal treasury. No CNMI-specific modification to capital gains rates found in federal statute. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title48-section1801&num=0&edition=prelim |
| treasury | U.S. Treasury interest | Exempt: 31 U.S.C. § 3124 prohibits state/territory taxation of U.S. obligations; Mirror Code does not override federal preemption | sources (1)48 U.S.C. § 1801, Covenant to Establish a Commonwealth of the CNMI, § 601 (Pub. L. 94-241, 90 Stat. 263 (1976)) · high confidence · as of 2026-06-19 · TY 2025 CNMI Mirror Code: federal income tax laws apply in CNMI as territorial income tax, in the same manner as Guam Section 601. (a) The income tax laws in force in the United States will come into force in the Northern Mariana Islands as a local territorial income tax on the first day of January following the effective date of this Section, in the same manner as those laws are in force in Guam. Note: The CNMI Mirror Code operates via the Guam Mirror Code (48 U.S.C. § 1421i) as the template. IRC references to 'Guam' automatically extend to CNMI per § 601(c): 'References in the Internal Revenue Code to Guam will be deemed also to refer to the Northern Mariana Islands, where not otherwise distinctly expressed or manifestly incompatible with the intent thereof or of this Covenant.' This incorporates the full Subtitle A of the IRC, including IRC § 1(h) (the 0%/15%/20% LTCG rate schedule) and the 12-month holding period under IRC § 1222. Tax is paid to the CNMI government, not the federal treasury. No CNMI-specific modification to capital gains rates found in federal statute. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title48-section1801&num=0&edition=prelim |
| qoz-conformity | QOZ conformity (IRC § 1400Z-2) | Conforms: IRC § 1400Z-2 is part of Subtitle A, incorporated by 48 U.S.C. § 1801 Mirror Code via Guam template | sources (1)48 U.S.C. § 1801, Covenant to Establish a Commonwealth of the CNMI, § 601 (Pub. L. 94-241, 90 Stat. 263 (1976)) · high confidence · as of 2026-06-19 · TY 2025 CNMI Mirror Code: federal income tax laws apply in CNMI as territorial income tax, in the same manner as Guam Section 601. (a) The income tax laws in force in the United States will come into force in the Northern Mariana Islands as a local territorial income tax on the first day of January following the effective date of this Section, in the same manner as those laws are in force in Guam. Note: The CNMI Mirror Code operates via the Guam Mirror Code (48 U.S.C. § 1421i) as the template. IRC references to 'Guam' automatically extend to CNMI per § 601(c): 'References in the Internal Revenue Code to Guam will be deemed also to refer to the Northern Mariana Islands, where not otherwise distinctly expressed or manifestly incompatible with the intent thereof or of this Covenant.' This incorporates the full Subtitle A of the IRC, including IRC § 1(h) (the 0%/15%/20% LTCG rate schedule) and the 12-month holding period under IRC § 1222. Tax is paid to the CNMI government, not the federal treasury. No CNMI-specific modification to capital gains rates found in federal statute. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title48-section1801&num=0&edition=prelim |
| qsbs-conformity | QSBS conformity (IRC § 1202) | Conforms: IRC § 1202 is part of Subtitle A, incorporated by 48 U.S.C. § 1801 Mirror Code via Guam template | sources (1)48 U.S.C. § 1801, Covenant to Establish a Commonwealth of the CNMI, § 601 (Pub. L. 94-241, 90 Stat. 263 (1976)) · high confidence · as of 2026-06-19 · TY 2025 CNMI Mirror Code: federal income tax laws apply in CNMI as territorial income tax, in the same manner as Guam Section 601. (a) The income tax laws in force in the United States will come into force in the Northern Mariana Islands as a local territorial income tax on the first day of January following the effective date of this Section, in the same manner as those laws are in force in Guam. Note: The CNMI Mirror Code operates via the Guam Mirror Code (48 U.S.C. § 1421i) as the template. IRC references to 'Guam' automatically extend to CNMI per § 601(c): 'References in the Internal Revenue Code to Guam will be deemed also to refer to the Northern Mariana Islands, where not otherwise distinctly expressed or manifestly incompatible with the intent thereof or of this Covenant.' This incorporates the full Subtitle A of the IRC, including IRC § 1(h) (the 0%/15%/20% LTCG rate schedule) and the 12-month holding period under IRC § 1222. Tax is paid to the CNMI government, not the federal treasury. No CNMI-specific modification to capital gains rates found in federal statute. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title48-section1801&num=0&edition=prelim |
| agency-obligations | FNMA/FHLMC bond interest | Taxable: CNMI Mirror Code incorporates IRC gross income rules; FNMA/FHLMC interest is in federal gross income; 31 U.S.C. §3124 preempts only direct U.S. government obligation taxation; FNMA/FHLMC are GSEs without a bondholder exemption | sources (1)31 U.S.C. § 3124 · medium confidence · as of 2026-06-20 · TY 2025 CNMI taxes FNMA and FHLMC bond interest: CNMI Mirror Code incorporates federal IRC including gross income rules; 31 U.S.C. §3124 preempts only direct U.S. obligation taxation; FNMA/FHLMC are not U.S. government obligations Stocks and obligations of the United States Government are exempt from taxation by a State or political subdivision of a State. The exemption applies to each form of taxation that would require the obligation, the interest on the obligation, or both, to be considered in computing a tax. Note: CNMI Mirror Code (48 U.S.C. § 1801, Covenant § 601) incorporates IRC Subtitle A via the Guam template: FNMA/FHLMC interest is in federal gross income (not IRC-excluded). 31 U.S.C. §3124 exempts only 'obligations of the United States Government'; FNMA and FHLMC are GSEs with no bondholder exemption statute. No CNMI DRT ruling found. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title31-section3124 |
| dividend-qualified | Qualified dividend rate (IRC §1(h)(11)) | Preferential: CNMI Form 1040CM carries the federal qualified-dividends line (3a) feeding the 0%/15%/20% worksheet, administering IRC §1(h)(11) under the Mirror Code; whether US mainland corporation dividends qualify under the domestic-corporation substitution remains without an authoritative DRT ruling | sources (2)CNMI Department of Finance, Division of Revenue and Taxation, Form 1040CM (2024), Northern Marianas Territorial Income Tax Return · medium confidence · as of 2026-07-12 · TY 2024 CNMI Form 1040CM mirrors the federal 1040 qualified-dividends line (3a), administering the IRC §1(h)(11) preferential rate under the NMTIT Northern Marianas Territorial Income Tax Return ... 3a Qualified dividends Note: Line 3a exists solely to feed the federal Qualified Dividends and Capital Gain Tax Worksheet (the 0%/15%/20% preferential computation), so the DRT form administers the §1(h)(11) preference in practice. TY2024 is the latest edition posted on finance.gov.mp as of the read date. Whether dividends from US MAINLAND corporations qualify under mirror-code substitution (the 'domestic corporation' reading) remains without an authoritative DRT or IRS ruling; see the companion unresolved-substitution citation. https://finance.gov.mp/division-forms/revenue-taxation/2024/2024-1040-cm.pdf48 U.S.C. § 1801 (Covenant § 601); 48 U.S.C. § 1421i(d) · low confidence · as of 2026-07-03 · TY 2025 CNMI Mirror Code incorporates IRC §1(h)(11) but domestic-corporation substitution may exclude US mainland corporation dividends from the preferential rate; treatment unresolved The income-tax laws in force in the United States of America and those which may hereafter be enacted shall be held to be likewise in force in Guam. Note: CNMI uses a mirror-code tax system under the Covenant with the US; preferential rates from IRC §1(h)(11) apply as if the CNMI were a state. The uscode.house.gov page for 48 U.S.C. §1801 now returns docnotfound, so the URL was swapped to the working 48 U.S.C. §1421i(d)(1) page; the quote is the Guam mirror-code template that the CNMI Covenant §601 mirrors. Under mirror-code substitution, 'domestic corporation' in §1(h)(11) may be read as a CNMI-incorporated corporation; whether dividends from US mainland corporations qualify for preferential rates is unresolved; no authoritative IRS or CNMI DRT ruling exists. This differs from GU and VI where prior research found a clearer basis for preferential treatment. https://uscode.house.gov/view.xhtml?hl=false&edition=prelim&req=granuleid%3AUSC-prelim-title48-section1421i&num=0 |
| fhlb-ffcb | FHLB and FFCB bond interest | Exempt: FHLB and FFCB securities are federal instrumentalities under 12 U.S.C. §1433 and §2023; their income is exempt from CNMI territorial taxation under the Supremacy Clause (U.S. Const. art. VI, cl. 2); medium confidence, no CNMI DRT ruling found | sources (2)12 U.S.C. §1433 (Federal Home Loan Bank Act); 12 U.S.C. §2023 (Farm Credit Act) · medium confidence · as of 2026-06-20 · TY 2025 FHLB and FFCB bond interest exempt from CNMI taxation: federal enabling statutes mandate state tax exemption Any security issued under this chapter by a Federal home loan bank, including the stock thereof, shall be exempt from taxation, except taxes upon real estate, by any State, county, municipality, or local taxing authority. Note: 12 U.S.C. §1433 says 'any State, county, municipality, or local taxing authority'; that clause refers to sub-state political subdivisions, not U.S. territories. CNMI is bound by §1433 and §2023 under the Supremacy Clause (U.S. Const. art. VI, cl. 2): federal enabling statutes bind territorial governments. See also constitutional intergovernmental tax immunity (McCulloch v. Maryland, 17 U.S. 316 (1819)). No CNMI DRT ruling found. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title12-section1433&num=0&edition=prelim12 U.S.C. §2023 (Farm Credit Act) · high confidence · as of 2026-06-20 · TY 2025 Farm Credit Act: notes, bonds, debentures, and other obligations of Farm Credit Banks are instrumentalities of the United States exempt from all State, municipal, and local taxation The mortgages held by the Farm Credit Banks and the notes, bonds, debentures, and other obligations issued by the banks shall be considered and held to be instrumentalities of the United States and, as such, they and the income therefrom shall be exempt from all Federal, State, municipal, and local taxation, other than Federal income tax liability of the holder thereof under the Public Debt Act of 1941 (31 U.S.C. 3124). Note: 12 U.S.C. §2023 explicitly covers 'the income therefrom' (i.e., interest payments to bondholders), exempting it from all State and local taxation. The only carve-out is federal income tax on the holder. Parallel to 12 U.S.C. §1433 (FHLB Act), which exempts FHLB securities from state taxation. Together §1433 and §2023 mandate state and local tax exemption for both FHLB and FFCB bond interest. Shared across all jurisdictions: a single object reference satisfies buildCitationIndex() identity check. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title12-section2023&num=0&edition=prelim |
| filing-status-partial | Filing status: partial MFJ bracket widening (mirrors federal via Guam) | Yes: CNMI Mirror Code (Covenant §601(a), 48 U.S.C. §1801) adopts the federal income tax bracket structure in the same manner as Guam; MFJ bracket thresholds are partially wider than single filer (not fully doubled at higher income), mirroring the federal structure. | sources (1)48 U.S.C. § 1801, Covenant to Establish a Commonwealth of the CNMI, § 601 (Pub. L. 94-241, 90 Stat. 263 (1976)) · high confidence · as of 2026-06-19 · TY 2025 CNMI Mirror Code: federal income tax laws apply in CNMI as territorial income tax, in the same manner as Guam Section 601. (a) The income tax laws in force in the United States will come into force in the Northern Mariana Islands as a local territorial income tax on the first day of January following the effective date of this Section, in the same manner as those laws are in force in Guam. Note: The CNMI Mirror Code operates via the Guam Mirror Code (48 U.S.C. § 1421i) as the template. IRC references to 'Guam' automatically extend to CNMI per § 601(c): 'References in the Internal Revenue Code to Guam will be deemed also to refer to the Northern Mariana Islands, where not otherwise distinctly expressed or manifestly incompatible with the intent thereof or of this Covenant.' This incorporates the full Subtitle A of the IRC, including IRC § 1(h) (the 0%/15%/20% LTCG rate schedule) and the 12-month holding period under IRC § 1222. Tax is paid to the CNMI government, not the federal treasury. No CNMI-specific modification to capital gains rates found in federal statute. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title48-section1801&num=0&edition=prelim |