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[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 858 Introduced in House (IH)]
<DOC>
119th CONGRESS
1st Session
H. R. 858
To amend the Internal Revenue Code of 1986 to determine global
intangible low-taxed income without regard to certain income derived
from services performed in the Virgin Islands.
_______________________________________________________________________
IN THE HOUSE OF REPRESENTATIVES
January 31, 2025
Mr. Estes (for himself, Ms. Plaskett, Mr. Hern of Oklahoma, Ms. Sewell,
Mr. Feenstra, and Mr. Schneider) introduced the following bill; which
was referred to the Committee on Ways and Means
_______________________________________________________________________
A BILL
To amend the Internal Revenue Code of 1986 to determine global
intangible low-taxed income without regard to certain income derived
from services performed in the Virgin Islands.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ``Restore Economic Vitality and
Investment in the Virgin Islands Act'' or the ``REVIVE VI Act''.
SEC. 2. GLOBAL INTANGIBLE LOW-TAXED INCOME DETERMINED WITHOUT REGARD TO
CERTAIN INCOME DERIVED FROM SERVICES PERFORMED IN THE
VIRGIN ISLANDS.
(a) In General.--Section 951A(c)(2)(A)(i) of the Internal Revenue
Code of 1986 is amended by striking ``and'' at the end of subclause
(IV), by striking the period at the end of subclause (V) and inserting
``, and'', and by adding at the end the following new subclause:
``(VI) in the case of any specified
United States shareholder, any
qualified Virgin Islands services
income.''.
(b) Definitions and Special Rules.--Section 951A(c)(2) of such Code
is amended by adding at the end the following new subparagraph:
``(C) Provisions related to qualified virgin
islands services income.--For purposes of subparagraph
(A)(i)(VI)--
``(i) Qualified virgin islands services
income.--The term `qualified Virgin Islands
services income' means any gross income which
satisfies all of the following requirements:
``(I) Such gross income is
compensation for labor or personal
services (within the meaning of section
862(a)(3)) performed in the Virgin
Islands by a corporation formed under
the laws of the Virgin Islands.
``(II) Such gross income is
attributable to services performed from
within the Virgin Islands by
individuals for the benefit of such
corporation.
``(III) Such gross income is
effectively connected with the conduct
of a trade or business within the
Virgin Islands.
``(ii) Specified united states
shareholder.--The term `specified United States
shareholder' means any United States
shareholder which is--
``(I) an individual, trust, or
estate, or
``(II) a closely held C corporation
(as defined in section 469(j)(1)) if
such corporation acquired its direct or
indirect equity interest in the foreign
corporation which derived the qualified
Virgin Islands services income before
December 31, 2023.
``(iii) Regulations.--The Secretary shall
prescribe such regulations or other guidance as
may be necessary or appropriate to carry out
this subparagraph and subparagraph (A)(i)(VI),
including regulations or other guidance to
prevent the abuse of such subparagraphs.''.
(c) Effective Date.--The amendments made by this section shall
apply to taxable years of foreign corporations beginning after the date
of the enactment of this Act, and to taxable years of United States
shareholders with or within which such taxable years of foreign
corporations end.
<all>
Introduced in House
Introduced in House
Referred to the House Committee on Ways and Means.
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