H.R. 858

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 858 Introduced in House (IH)]

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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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