joined by COMPTON, Justice, dissenting.
I dissent from Part II. A. of the court’s opinion which addresses the issue of sovereign immunity. In my view Congress has never stated with sufficient clarity an intent to waive the sovereign immunity of Alaska Native villages. While I agree that the federal government has never expressly recognized Alaska Native villages as tribes for purposes of sovereign immunity, it is firmly established that a historically sovereign tribe is immune from suit, even in the absence of federal recognition, until Congress or the tribe expressly waives its immunity. Accordingly, I would remand this case for a factual determination as to whether Stevens Village possesses the attributes of a sovereign Indian tribe that would entitle it to sovereign immunity.1
I.
The court holds that “Congress has demonstrated its intent that Alaska Native communities not be accorded sovereign tribal status,” and that therefore “Stevens Village is not entitled to utilize the defense of tribal sovereign immunity.” It is true that if Congress waived the Village’s sovereign immunity, the Village would be barred from utilizing this defense. “[Tjribal sovereignty ... is subject to the superior and plenary control of Congress.” Santa Clara Pueblo v. Martinez, 436 U.S. 49, 58, 98 S.Ct. 1670, 1677, 56 L.Ed.2d 106, 115 (1978).
However, if Congress is to waive2 a tribe’s sovereign immunity, it must clearly *44express this intent: “It is settled that a waiver of sovereign immunity ‘cannot be implied but must be unequivocally expressed.’ ” Id. (emphasis added; citation omitted). Accordingly, the Ninth Circuit Court of Appeals has “rejected the contention that congressional enactments unrelated to immunity may implicitly grant authority to bring suit against Indian tribes.” Chemehuevi Indian Tribe v. California State Bd. of Equalization, 757 F.2d 1047, 1053 (9th Cir.) (compulsory counterclaim requirement of Rule 13(a) of the Federal Rules of Civil Procedure held not to be waiver of tribal immunity), rev’d on other grounds, 474 U.S. 9, 106 S.Ct. 289, 88 L.Ed.2d 9 (1985).
This court has previously recognized these principles. In Atkinson v. Haldane, 569 P.2d 151, 167 (Alaska 1977), we stated: “[Sovereign immunity ... [is] waived only if it is clear from the unambiguous language of [the statute] and its legislative history that Congress intended such a waiver.” In the case at bar, the court fails to observe these canons and infers a congressional waiver of immunity from a battery of enactments that do not address the issue of sovereign immunity.
The court first cites numerous pre-1936 enactments and judicial decisions suggesting that Native villages were at that time subject to state law and not considered “Indian country.” None of these enactments, however, contained an express waiver of sovereign immunity. When Congress subjects an Indian tribe to state jurisdiction, it does not implicitly strip the tribe of its inherent sovereignty. For example, Public Law 280, 67 Stat. 588, 589 (1953) explicitly granted to certain states, including Alaska, extensive civil and criminal jurisdiction over Indian tribes. See 18 U.S. C.A. § 1162 (1984); 28 U.S.C.A. § 1360 (Supp.1987). Even this broad grant of jurisdiction, however, was not sufficient to waive sovereign immunity. The Supreme Court recently held: “We have never read Pub L 280 to constitute a waiver of tribal sovereign immunity, nor found Pub L 280 to represent an abandonment of the federal interest in guarding Indian self-governance.” Three Affiliated Tribes of the Fort Berthold Reservation v. Wold Engineering, 476 U.S. 877, 892, 106 S.Ct. 2305, 2314, 90 L.Ed.2d 881, 894 (1986). In short, state jurisdiction over an Indian tribe is not inconsistent with tribal sovereignty in general or with tribal sovereign immunity in particular. Thus, nothing in any of the pre-1936 enactments cited by the court constitutes a waiver of sovereign immunity-
The court next turns to the Indian Reorganization Act (IRA), 25 U.S.C.A. §§ 461-479 (1983). The court cites no provision of the Act which remotely resembles a waiver of sovereign immunity.3 Indeed, it is somewhat perplexing even to infer a waiver from the provisions of the IRA. One of the clear purposes of the IRA was to revitalize tribal self-government, see, e.g., Mescalero Apache Tribe v. Jones, 411 U.S. 145, 151-52, 93 S.Ct. 1267, 1272, 36 L.Ed.2d 114, 121 (1973), and sovereign immunity “is a necessary corollary to Indian sovereignty and self-governance.” Three Affiliated Tribes, 476 U.S. at 890, 106 S.Ct. at 2313, 90 L.Ed.2d at 894. The United States Supreme Court has held that “[t]he Reorganization Act did not strip Indian tribes ... of their historic immunity from state and local control.” Mescalero Apache Tribe, 411 U.S. at 152, 93 S.Ct. at 1267, 36 L.Ed.2d at 121.4 Although I agree with the court’s *45conclusion that IRA incorporation alone does not constitute federal recognition of tribal status, see infra note 6, I cannot agree that this Act, when combined with the previous enactments, somehow constitutes a waiver of sovereign immunity.
Similarly, in ANCSA, the final enactment considered by the court, Congress did not address immunity. The court does not cite a single provision of ANCSA that directly or indirectly suggests a waiver of sovereign immunity. Rather, the court infers this intent, an approach which is at odds with the rule that a waiver of immunity must be clearly expressed.
One of the provisions the court uses to bolster its waiver conclusion is the section that permits taxation of certain lands granted pursuant to ANCSA. 43 U.S.C.A. § 1620(d) (1986). In my view this section supports the opposite conclusion, because it is an excellent example of the type of clear expression Congress must make to waive an immunity, in this case tax immunity.
The court concludes that ANCSA “evidences Congress’s intent that non-reservation villages be largely subject to state law.” Even assuming that this is true, it does not deprive the villages of sovereign immunity. As discussed above in connection with the earlier enactments and Public Law 280, Congress does not necessarily waive the sovereign immunity of Indian tribes when it subjects them to some measure of state law.5
In short, nothing in ANCSA, the IRA, or any of the earlier enactments approaches the type of express congressional statement that is necessary to waive sovereign immunity. Thus, if Stevens Village is a “tribe” under common law principles of tribal sovereign immunity, this court lacks jurisdiction to adjudicate the claim in the instant case.
II.
The court also concludes that an Indian tribe may not avail itself of sovereign immunity in the absence of express recognition of tribal status by either Congress or the executive branch of the federal government. This argument has been considered and rejected by the federal courts, is inconsistent with the underlying basis of the doctrine of tribal sovereign immunity, and is not supported by our own decisions.6
*46In support of its express federal recognition analysis, the court relies on Atkinson v. Haldane, 569 P.2d 151 (Alaska 1977). However, as we noted in Atkinson, sovereign immunity is a federal doctrine, and this court is bound under the supremacy clause, U.S. Const, art. VI, cl. 2, to follow the holdings of the United States Supreme Court. 596 P.2d at 163.
In my opinion the position taken by the court in regard to the necessity for express federal recognition is in direct conflict with federal law. The First Circuit Court of Appeals faced this issue directly and, relying on Supreme Court precedent, concluded that express or implied federal recognition was not necessary to establish sovereign immunity.
We are cited to, and our research has uncovered, no case which conditions the invocation of sovereign immunity on the factors emphasized by the state or appellant: formal federal recognition of the particular tribe by treaty or statute, a prolonged course of dealing between the tribe and the federal government, geographic location, the tribe’s warlike nature, the absence of state protection of a tribe or the continued full exercise of a tribe’s sovereign powers.
The absence of authority is not surprising, for the analysis urged by appellant and the state seems to us to fundamentally misconceive basic principles of federal Indian law. In effect, their approach would condition the exercise of an aspect of sovereignty on a showing that it had been granted to the tribe by the federal government, either by explicit recognition or implicitly through a course of dealing. As the Supreme Court recently explained, however, the proper analysis is just the reverse:
“The powers of Indian tribes are, in general, ‘inherent powers of a limited sovereignty which has never been extinguished.’ F. Cohen, Handbook of Federal Indian Law 122 (1945) (emphasis in original)
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“Indian tribes are, of course, no longer ‘possessed of the full attributes of sovereignty.’ ... Their incorporation within the territory of the United States, and their acceptance of its protection, necessarily divested them of some aspects of the sovereignty which they had previously exercised. By specific treaty provision they yielded up other sovereign powers; by statute, in the exercise of its plenary control, Congress has removed still others.
“But our cases recognize that the Indian tribes have not given up their full sovereignty.... The sovereignty that the Indian tribes retain is of a unique and limited character. It exists only at the sufferance of Congress and is subject to complete defeasance. But until Congress acts, the tribes retain their existing sovereign powers. In sum, Indian tribes still possess those aspects of sovereignty not withdrawn by treaty or statute, or by implication as a necessary result of their dependent status
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Bottomly v. Passamaquoddy Tribe, 599 F.2d 1061, 1065-66 (1st Cir.1979) (quoting United States v. Wheeler, 435 U.S. 313, 322-23, 98 S.Ct. 1079, 1085-86, 55 L.Ed.2d 303, 312-13 (1978)) (emphasis in original or added by Bottomly court; footnotes omitted).7 Since Congress had not waived the tribe’s sovereign immunity, the court held that the doctrine barred the suit even though Congress had never explicitly or implicitly recognized the tribe. 599 F.2d at 1066.
Although the Supreme Court has never addressed this issue, analysis of that court’s relevant decisions leads to the same conclusion the First Circuit reached. Im*47munity from suit is one attribute of sovereignty retained by Indian tribes, which are sovereign entities predating annexation by the United States. “It is as though the immunity which was theirs as sovereigns passed to the United States for their benefit, as their tribal properties did.” United States v. United States Fidelity & Guar. Co., 309 U.S. 506, 512-13, 60 S.Ct. 653, 656, 84 L.Ed. 894, 899 (1940).
Therefore, there is no need for the federal government expressly to recognize the sovereignty of a tribe for the tribe to retain most attributes of its sovereignty. As the Supreme Court explained just last year, “Because the Tribe retains all inherent attributes of sovereignty that have not been divested by the Federal Government, the proper inference from silence ... is that the sovereign power ... remains intact.” Iowa Mut. Ins. Co. v. LaPlante, 480 U.S. 9, 107 S.Ct. 971, 978, 94 L.Ed.2d 10, 21 (1987) (quoting Merrion v. Jicarilla Apache Tribe, 455 U.S. 130, 149 n. 14, 102 S.Ct. 894, 907-08 n. 14, 71 L.Ed.2d 21, 37 n. 14 (1982)). See also Wheeler, 435 U.S. at 322-23, 98 S.Ct. at 1085-86, 55 L.Ed.2d at 312-13 (quoted above).
In the instant case Congress has neither expressly recognized the Village as a tribe for purposes of sovereign immunity nor expressly waived the Village’s immunity. Therefore, if the Village is in fact a historically sovereign tribe, this court is bound to honor its immunity from suit.
The court cites three Supreme Court cases pertaining to the subject of sovereign immunity: Three Affiliated Tribes of the Fort Berthold Reservation v. Wold Engineering, 476 U.S. 877, 890, 106 S.Ct. 2305, 2313, 90 L.Ed.2d 881, 894 (1986); Santa Clara Pueblo v. Martinez, 436 U.S. 49, 58, 98 S.Ct. 1670, 1677, 56 L.Ed.2d 106, 115 (1978); and U.S. Fidelity, 309 U.S. at 512-13, 60 S.Ct. at 656, 84 L.Ed. at 898-99. In each of these cases there was apparently some federal recognition of the tribe. However, there is no indication that the Court relied on this fact in finding the tribes entitled to sovereign immunity. None of the three cases explicitly mentions federal recognition of tribal status in their respective discussions of sovereign immunity. To the contrary, the discussion in each suggests that the basis of immunity ⅛ historical sovereign status rather than any federal recognition. See Three Affiliated Tribes, 476 U.S. at 890, 106 S.Ct. at 2313, 90 L.Ed.2d at 894 (“The common law sovereign immunity possessed by the Tribe is a necessary corollary to Indian sovereignty and self-governance.”); Santa Clara Pueblo, 436 U.S. at 58, 98 S.Ct. at 1677, 56 L.Ed.2d at 115 (“Indian tribes have long been recognized as possessing the common-law immunity from suit traditionally enjoyed by sovereign powers.”); U.S. Fidelity, 309 U.S. at 512, 60 S.Ct. at 656, 84 L.Ed. at 899 (“These Indian Nations are exempt from suit without congressional authorization. It is as though the immunity which was theirs as sovereigns passed to the United States for their benefit, as their tribal properties did.”).8
It is true that the basis of the finding of tribal sovereign immunity in Atkinson v. Haldane, 569 P.2d 151 (Alaska 1977) was express federal recognition. However, contrary to the implication of the court’s opinion today, nothing in the Atkinson opinion suggests that this is the only way sovereign immunity can be established. Once Congress or the executive branch has recognized a tribe, the question is nonjusti-ciable, and there is no further need for the court to explore the historical basis for the finding of sovereignty. As we explained, “Once the executive branch has determined that the Metlakatla Indian Community is an Indian tribe, which is a nonjusticiable political question, the Community is entitled to all the benefits of tribal status.” Id. at 163. Even in the absence of such recognition, however, we remain bound to honor the sovereignty of a historical Indian tribe. We recognized this implicitly in describing immunity from suit as a “retain[ed] ... vestige[ ]” of a formerly complete sovereignty. Id. at 160.
III.
Having determined that the federal government has not expressly recognized Stevens Village as a tribe for purposes of *48sovereign immunity, I would remand the case to afford the Village the opportunity to make a factual showing as to its alleged tribal status.
It appears that no court has ever fashioned a definition of “tribe” specifically for purposes of determining sovereign immunity. Unfortunately, reference to definitions of “tribe” for other purposes does not necessarily provide a definitive answer in the sovereign immunity context. A leading authority explains:
The term tribe has no universal legal definition. There is no single federal statute defining an Indian tribe for all purposes, although the Constitution and many federal statutes and regulations make use of the term. In most instances the question of tribal existence can be resolved by reference to a treaty, statute, executive order, or agreement recognizing the tribe in question. In other cases the definition of tribe, like many other such generic terms, will depend in part on the context and purposes for which the term is used.
Felix S. Cohen’s Handbook of Federal Indian Law 3 (R. Strickland ed. 1982) (footnote omitted).
One of the most often cited definitions of “tribe” appears in Montoya v. United States, 180 U.S. 261, 21 S.Ct. 358, 45 L.Ed. 521 (1901), a case not involving sovereign immunity. In that case, the Supreme Court stated, “By a ‘tribe’ we understand a body of Indians of the same or a similar race, united in a community under one leadership or government, and inhabiting a particular though sometimes ill-defined territory....” Id. at 266, 21 S.Ct. at 359, 45 L.Ed. at 523. Some modern courts have followed this definition for other purposes. See Mashpee Tribe v. Secretary of the Interior, 820 F.2d 480, 482 (1st Cir.1987); Joint Tribal Council of the Passamaquoddy Tribe v. Morton, 528 F.2d 370, 377 n. 8 (1st Cir.1975).
I think this definition sets forth minimum requirements for tribal sovereign immunity. As discussed above, however, immunity from suit derives from the sovereignty that a tribe possessed at the time the United States asserted its superior sovereignty. Thus, in addition to the requirements of the Montoya definition, there is also a need for a showing of historical sovereignty.
The Bureau of Indian Affairs (BIA) has considered this question in adopting regulations to acknowledge the existence of Indian tribes entitled to the “immunities and privileges” of other recognized tribes. 25 C.F.R. § 83.2 (1987). Presumably sovereign immunity is among the immunities recognized. It appears that the BIA has not recognized IRA corporations in Alaska as tribes pursuant to these regulations.9 *49Nevertheless, these regulations can provide significant guidance in the present inquiry.
The factors considered by the BIA in these regulations are: historical identification as “American Indian” or “aboriginal,” 25 C.F.R. § 83.7(a); historical habitation of a particular area or community, id. § 83.-7(b); historical political influence or authority over members, id. § 83.7(c); established though not necessarily written governing procedures and membership criteria, id. § 83.7(d); and a membership consisting primarily of descendants of a distinct historical tribe not members of any other North American tribe. Id. § 83.7(e) & (f). These requirements essentially track the Montoya definition, with the added requirement that each element of the test be shown to have existed historically.10 In Price v. Hawaii, 764 F.2d 623, 627 (9th Cir.1985) the Ninth Circuit employed these factors in determining tribal status for purposes of federal court jurisdiction under 28 U.S.C. § 1362.
In my view the BIA standards provide an appropriate test for determining whether an entity is a tribe for purposes of sovereign immunity. I am not unmindful of the fact that these factors were developed with the experiences and characteristics of Indians in the lower 48 states in mind. Therefore, I would view these factors merely as guidelines that may be tailored to accommodate the unique history and circumstances of Native groups in Alaska. Thus our trial courts should consider other factors that may be relevant in determining whether a particular Alaska Native group has proved its tribal status.11
AMP argues that Stevens Village did not meet its burden of proof because it did not present any evidence of its historical tribal status. The Village responds that it has “reams of documentation,” but declined to present it in the trial court because AMP did not contest the Village’s tribal status. The record is incomplete and does not clearly reveal the arguments that AMP made in the superior court. However, neither party could easily have anticipated the standards this court would adopt in proving tribal status. Given the importance of the issue presented, I would remand to provide Stevens Village with the opportunity to prove its historical tribal status under the standards set forth above.
IV.
As stated earlier I agree with the court that there has never been any express federal recognition of Alaska Native villages as tribes for purposes of sovereign immunity. However, it is equally clear that Congress has never expressly denied sovereign immunity to these villages. The unfortunate but inescapable fact is that Congress has steadfastly avoided defining the extent and limits of Native sovereignty in Alaska. Illustrative of this fact are the recent “1991” amendments to ANCSA, in which Congress declared, “[N]o provision of this Act shall ... confer on, or deny to, any Native organization any degree of sovereign governmental authority over lands ... or persons in Alaska....” Alaska Native Claims Settlement Act Amendments of 1987, Pub.L. No. 100-241, § 2(8)(B), 101 Stat. 1788, 1789 (1988). See also id. § 17(a), 101 Stat. 1814. The Senate Report on the bill stated:
It is the Committee’s clear intent that this bill leave parties in the sovereignty issue, in exactly the same status as if the amendments were not enacted.
*50This is an issue which should be left to the courts in interpreting applicable law and that these amendments should play no substantive or procedural role in such court decisions.
S.Rep. No. 201, 100th Cong., 1st Sess. 23 (1987), U.S.Code Cong. & Admin.News 1988, pp. 3269, 3274.
Thus, it appears that Congress has chosen to abdicate to the courts on this issue. In the absence of any express federal recognition or waiver of sovereign immunity, this court is bound to follow the common law principles of tribal sovereign immunity announced by the Supreme Court. In my view the court’s opinion fails to do this.
. In an unpublished decision, the Federal District Court for the District of Alaska recently addressed the precise issue presented in the instant case. See Native Village of Tyonek v. Puckett, No. A82-369 Civil, transcript of decision (D.Alaska Dec. 3, 1986). In that case, the Native Village of Tyonek, an IRA section 16 corporation, was attempting as plaintiff to enforce a Village ordinance prohibiting non-members from residing in the Village. The defendants counterclaimed, but the court concluded that the counterclaim was barred by sovereign immunity.
The federal court persuasively and expressly rejected the two principal arguments made by
the court in the instant case: (1) that federal recognition is a prerequisite to tribal sovereign immunity, id. at 23, and (2) that the Alaska Native Claims Settlement Act (ANCSA), 43 U.S. C.A. §§ 1601-1629a (1986), was a waiver of "the immunity of village governments organized under IRA section 16.” Id. at 24 n. 13. After carefully considering the history of the Village and the effects of ANCSA, id. at 4-9, the District Court concluded that the Village was entitled to sovereign immunity, which neither it nor Congress had waived. Id. at 30.
. The court’s opinion does not explain whether Congress waived or discontinued the villages’ sovereign immunity, or somehow declared that the immunity never existed. Whatever the case may be, any congressional expression of intent must meet the strict standard applied to waiver. Any lesser standard would run afoul of the settled principle that "statutes passed for the *44benefit of dependent Indian tribes ... are to be liberally construed, doubtful expressions being resolved in favor of the Indians." Bryan v. Itasca County, 426 U.S. 373, 392, 96 S.Ct. 2102, 2112, 48 L.Ed.2d 710, 723 (1976) (quoting Alaska Pac. Fisheries v. United States, 248 U.S. 78, 89, 39 S.Ct. 40, 42, 63 L.Ed. 138, 141 (1918)).
. The court finds in the Alaska amendment to the IRA "an express Congressional statement applicable to most Native groups in Alaska that they had not been recognized as tribes." See 25 U.S.C.A. § 473a (1983). It is true that this section acknowledges that some Native groups had not been recognized as tribes as of 1936. However, the lack of federal recognition of tribal status is not fatal to a tribe’s claim of sovereign immunity. See infra Part II. In my view, this section is not an "unequivocal expression” of Congress’s intent to waive the villages' sovereign immunity.
. The court suggests that Alaska Native villages incorporated under IRA section 16 possess no governmental powers because they were never granted reservations. I disagree for two reasons. First, this argument nullifies the plain language of the Alaska amendment to the IRA, which on its face allows "groups of Indians in Alaska” to incorporate under section 16 without any mention of reservations. See 25 U.S.C.A. § 473a (1983).
*45Second, this argument would negate many constitutions approved under section 16, including that of Stevens Village, which explicitly grant powers of self-government even in the absence of a reservation. The Constitution of the Native Village of Stevens grants the Village the power "[t]o do all things for the common good which it has done or has had the right to do in the past....” Constitution and By-laws of the Native Village of Stevens, art. IV, § 1. Thus, the power to control the use of any reservation was merely one component of a much broader grant of power. If the Village historically exercised powers of a sovereign tribe not inconsistent with applicable federal and territorial law, its constitution clearly grants it the power to continue in this capacity.
I further disagree with the court’s conclusion that the Alaska Native Claims Settlement Act (ANCSA), 43 U.S.C.A. §§ 1601-1629a (1986), demonstrates Congress's intent that IRA corporations in Alaska "were [not] meant to have a role in local government.” Local self-government was the very purpose of IRA section 16 corporations, and there is no indication whatsoever that Congress intended ANCSA to repeal IRA section 16 in Alaska. If IRA corporations were to have no further role in local government, it is difficult to explain why the Native Village of Stevens coordinated the electrification project in the instant case, with the cooperation of the federal Department of Housing and Urban Development. The record leaves no doubt that Stevens Village in fact continues to serve a governmental role with the assistance of federal agencies.
. Recently this court again recognized that ambiguities in ANCSA, as in other federal statutes for the benefit of Indians, are to be construed in favor of the Indians. Hakala v. Atxam Corp., 753 P.2d 1144, 1147 (Alaska, 1988).
. I agree with the court that IRA incorporation alone does not constitute federal recognition of tribal status for purposes of sovereign immunity, but my reasons are somewhat different.
As the court’s opinion notes, the Alaska amendment to the IRA allowed any "group[ ] of Indians in Alaska” with a "common bond” to incorporate. 25 U.S.C.A. § 473a (1983). The "common bond” language is extremely broad. In fact, it is nearly identical to that in a previously-enacted statute providing for the organization of federal credit unions having nothing to do with Indians. 12 U.S.C.A. § 1759 (1980). Whether or not so intended by Congress, the expansive "common bond” language has resulted in reorganization under IRA section 16 of Alaska Native groups that clearly had no histori*46cal existence as tribal governmental units. For example, the Ketchikan Indian Corporation is organized under both IRA sections 16 and 17. Yet its members "are not descended from any particular Indian community, but are natives of differing groups who happen to live in Ketchikan.” Board of Equalization v. Alaska Native Bhd. and Sisterhood, Camp. No. 14, 666 P.2d 1015, 1025 (Alaska 1983) (Rabinowitz, J., concurring). Therefore, it seems unlikely that Congress intended to recognize all IRA section 16 corporations as tribes for purposes of sovereign immunity.
. Accord Board of Equalization v. Alaska Native Bhd. and Sisterhood, Camp No. 14, 666 P.2d 1015, 1024 (Alaska 1983) (Rabinowitz, J., concurring).
. See also United States v. Oregon, 657 F.2d 1009, 1013 (9th Cir.1981) ('Indian tribes enjoy immunity because they are sovereigns predating the constitution, and immunity is thought necessary to preserve autonomous tribal existence.") (per Kennedy, J.).
. Alaska Native groups are eligible to petition for tribal recognition under these regulations "on the same basis as groups in the lower 48 States." 43 FedJReg. 39,361 (1978). Although the procedures originally provided that Alaska IRA corporations were not among those Alaska Native groups eligible to petition, id., the BIA published a list in 1982 that include numerous Alaska IRA corporations, including Stevens Village. 47 Fed.Reg. 53,133, 53,135 (1982). This list, which was separate from the list of recognized lower 48 tribes, was entitled “Alaska Native Entities Recognized and Eligible to Receive Services From the United States Bureau of Indian Affairs.” Id. at 53,133. Following this caption was an explanation of the purpose of the list:
While eligibility for services administered by the Bureau of Indian Affairs is generally limited to historical tribes and communities. of Indians residing on reservations, and their members, unique circumstances have made eligible additional entities in Alaska winch are not historial [sic] tribes. Such circumstances have resulted in multiple, overlapping eligibility of native entities in Alaska. To alleviate any confusion which might arise from publication of a multiple eligibility listing, the following preliminary list shows those entities to which tiie Bureau of Indian Affairs gives priority for purposes of funding and services.
Id at 53,133-34. In subsequent years, the BIA has continued the practice of listing Alaska “Native Entities” separately from lower 48 tribes, although the 1982 explanation quoted above has not been republished. See 50 Fed.Reg. 6058 (1985); 51 Fed.Reg. 25,118 (1986).
Thus it appears that the BIA has listed Alaska Native groups eligible for services, but has explicitly declined to specify which groups in Alaska might be recognized as historical tribes. See also Board of Equalization v. Alaska Native Bhd and Sisterhood, Camp No. 14, 666 P.2d 1015, 1024 n. 2 (Rabinowitz, J., concurring). But see Report of the Governor’s Task Force on Federal-State-Tribal Relations 65-66 (Feb. 14, 1986) (citing unwritten communications from Ulterior Department officials stating that deletion of above-quoted explanation was specifically intended as recognition of entities as tribes).
. Obviously no IRA section 16 corporations existed before 1934, but this is not fatal to such a corporation’s showing of historical tribal sovereignty. The framework of a tribal government may change or even dissolve without extinguishing sovereign immunity. “The public policy which exempted the dependent as well as the dominant sovereignties from suit without consent continues this immunity even after dissolution of the tribal government.’’ U.S. Fidelity, 309 U.S. at 512, 60 S.Ct. at 656, 84 L.Ed. at 898-99 (emphasis added; footnote omitted).
. This view of the sovereignty of Native villages is consistent with a decided trend in federal legislation to treat Alaska Natives on an equal basis with Indians in the lower 48 states. See, e.g., Indian Self-Determination Act, 25 U.S.C.A. § 450b(b) (1983) (definition of tribe includes an Alaska Native village or regional or village corporation established pursuant to ANCSA); Indian Financing Act, 25 U.S.C.A. § 1452(c) (1983) (same); Indian Child Welfare Act, 25 U.S.C.A. § 1903(8) (1983) (definition of tribe includes Alaska Native villages as defined in 43 U.S.C. § 1602(c)); Indian Tribal Governmental Tax Status Act, 26 U.S.C.A. § 7701(a)(40)(A) (Supp. 1988) (definition of tribe includes Alaska Native entities whom the Secretary of the Interior deems to be exercising governmental functions).