Bill > HR858

This bill amends the Internal Revenue Code to modify how global intangible low-taxed income (GILTI) is calculated by excluding certain income derived from services performed in the Virgin Islands. Specifically, the bill introduces a new category called "qualified Virgin Islands services income" which includes gross income that meets three key criteria: (1) it is compensation for labor or personal services performed in the Virgin Islands by a corporation formed under Virgin Islands law, (2) the income is attributable to services performed within the Virgin Islands by individuals for the benefit of that corporation, and (3) the income is effectively connected with a trade or business within the Virgin Islands. The bill applies to specific United States shareholders, including individuals, trusts, estates, and closely held C corporations that acquired their equity interest in the foreign corporation before December 31, 2023. The legislation, referred to as the "REVIVE VI Act" (Restore Economic Vitality and Investment in the Virgin Islands Act), directs the Secretary of the Treasury to develop regulations to implement these changes and prevent potential abuse. The amendments will take effect for taxable years of foreign corporations beginning after the date of the Act's enactment.

Budget and Finance

https://www.congress.gov/bill/119th-congress/house-bill/858/all-info