Yes, it is American land currently occupied by a foreign power. The DOD Law of War manual goes into this in detail (Chapter 18, I believe).
Thanks ill.check that out- I probsbly won’t understand much, but it seems odd to me that after having fought as hard as we did, that we should give up land to foreigners like that. Especially foreigners that we escaped from because of their tyranny over out lives back in Brittain before we left.