Armstrong

I.

BACKGROUND

A. The CNMI Covenant and adoption of federal tax law as a local territorial tax system

From 1947 until 1986, what is now the CNMI was a trust territory administered by the United States pursuant to an agreement with the Security Council of the United Nations. See generally Joseph E. Horey, The Right of Self-Government in the Commonwealth of the Northern Mariana Islands, 4 Asian-Pac. Law & Policy Journal 180, 181 (2003) (providing brief overview of CNMI history); see also 48 U.S.C. § 1801

enant, the district court had jurisdiction pursuant to Covenant § 903, reprinted in 48 U.S.C. § 1801 (note), which provides that “[n]othing herein shall prevent the presentation of cases or controversies arising under this Covenant to courts established by the Constitution or laws of the United States.” At oral argument, however, Armstrong withdrew this additional argument. We therefore need not address either its merits or whether, as the CNMI contends, Armstrong waived the argument by not raising it in the district court or in her opening brief. 10652 ARMSTRONG v CNMI (quoting language of Pub. L. 94-241, describing trusteeship terms); United States v. De Leon…