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 cer-
tain income derived from services performed in the Vir-
gin Islands. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Restore Economic Vi-
tality and Investment in the Virgin Islands Act’’ or the 
‘‘REVIVE VI Act’’. 
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SEC. 2. GLOBAL INTANGIBLE LOW-TAXED INCOME DETER-
MINED WITHOUT REGARD TO CERTAIN IN-
COME 
DERIVED 
FROM 
SERVICES 
PER-
FORMED 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 quali-
fied 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 pur-
poses 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 fol-
lowing requirements: 
‘‘(I) Such gross income is com-
pensation for labor or personal serv-
ices (within the meaning of section 
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862(a)(3)) performed in the Virgin Is-
lands by a corporation formed under 
the laws of the Virgin Islands. 
‘‘(II) Such gross income is attrib-
utable to services performed from 
within the Virgin Islands by individ-
uals for the benefit of such corpora-
tion. 
‘‘(III) Such gross income is effec-
tively connected with the conduct of a 
trade or business within the Virgin Is-
lands. 
‘‘(ii) 
SPECIFIED
UNITED
STATES 
SHAREHOLDER.—The 
term 
‘specified 
United States shareholder’ means any 
United States shareholder which is— 
‘‘(I) an individual, trust, or es-
tate, 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 quali-
fied Virgin Islands services income be-
fore December 31, 2023. 
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