119-hr858

[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.
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