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[Congressional Bills 118th Congress]
[From the U.S. Government Publishing Office]
[H.R. 10503 Introduced in House (IH)]

<DOC>

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.

    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>
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