I 

118TH CONGRESS 

2D SESSION H. R. 10503 

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 

DECEMBER 18, 2024 

Ms. PLASKETT (for herself and Mr. ESTES) 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. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Restore Economic Vi5 tality and Investment in the Virgin Islands Act’’ or the 

6 ‘‘REVIVE VI Act’’. 


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1 SEC. 2. GLOBAL INTANGIBLE LOW-TAXED INCOME DETER2 MINED WITHOUT REGARD TO CERTAIN IN3 COME DERIVED FROM SERVICES PER4 FORMED IN THE VIRGIN ISLANDS. 

5 (a) IN GENERAL.—Section 951A(c)(2)(A)(i) of the 

6 Internal Revenue Code of 1986 is amended by striking 

7 ‘‘and’’ at the end of subclause (IV), by striking the period 

8 at the end of subclause (V) and inserting ‘‘, and’’, and 

9 by adding at the end the following new subclause: 

10 ‘‘(VI) in the case of any specified 

11 United States shareholder, any quali12 fied Virgin Islands services income.’’. 

13 (b) DEFINITIONS AND SPECIAL RULES.—Section 

14 951A(c)(2) of such Code is amended by adding at the end 

15 the following new subparagraph: 

16 ‘‘(C) PROVISIONS RELATED TO QUALIFIED

17 VIRGIN ISLANDS SERVICES INCOME.—For pur18 poses of subparagraph (A)(i)(VI)— 

19 ‘‘(i) QUALIFIED VIRGIN ISLANDS

20 SERVICES INCOME.—The term ‘qualified 

21 Virgin Islands services income’ means any 

22 gross income which satisfies all of the fol23 lowing requirements: 

24 ‘‘(I) Such gross income is com25 pensation for labor or personal serv26 ices (within the meaning of section 


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1 862(a)(3)) performed in the Virgin Is2 lands by a corporation formed under 

3 the laws of the Virgin Islands. 

4 ‘‘(II) Such gross income is attrib5 utable to services performed from 

6 within the Virgin Islands by individ7 uals for the benefit of such corpora8 tion. 

9 ‘‘(III) Such gross income is effec10 tively connected with the conduct of a 

11 trade or business within the Virgin Is12 lands. 

13 ‘‘(ii) SPECIFIED UNITED STATES

14 SHAREHOLDER.—The term ‘specified 

15 United States shareholder’ means any 

16 United States shareholder which is— 

17 ‘‘(I) an individual, trust, or es18 tate, or 

19 ‘‘(II) a closely held C corporation 

20 (as defined in section 469(j)(1)) if 

21 such corporation acquired its direct or 

22 indirect equity interest in the foreign 

23 corporation which derived the quali24 fied Virgin Islands services income be25 fore December 31, 2023. 


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1 ‘‘(iii) REGULATIONS.—The Secretary 

2 shall prescribe such regulations or other 

3 guidance as may be necessary or appro4 priate to carry out this subparagraph and 

5 subparagraph (A)(i)(VI), including regula6 tions or other guidance to prevent the 

7 abuse of such subparagraphs.’’. 

8 (c) EFFECTIVE DATE.—The amendments made by 

9 this section shall apply to taxable years of foreign corpora10 tions beginning after the date of the enactment of this 

11 Act, and to taxable years of United States shareholders 

12 with or within which such taxable years of foreign corpora13 tions end. 

Æ 


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