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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.
Summary
This bill amends the Internal Revenue Code to exclude certain income from "global intangible low-taxed income" (GILTI) calculations for U.S. tax purposes. The bill creates an exclusion for "qualified Virgin Islands services income," which is compensation for labor or personal services performed in the Virgin Islands by a corporation formed under Virgin Islands law and effectively connected with a trade or business in the Virgin Islands. The exclusion applies only to specified United States shareholders, defined as individuals, trusts, estates, or closely held C corporations that acquired their interest before December 31, 2023. The Treasury Secretary must issue regulations to prevent abuse of this provision. The changes apply to taxable years of foreign corporations beginning after the bill's enactment.
AI-generated plain-language summary of the bill text — neutral, and may be imperfect. See the full text below for the exact wording.
Sponsor (1)
- Rep. Estes, Ron [R-KS-4] (R-KS)
8 cosponsors
- Del. Plaskett, Stacey E. [D-VI-At Large] (D-VI)
- Rep. DelBene, Suzan K. [D-WA-1] (D-WA)
- Rep. Feenstra, Randy [R-IA-4] (R-IA)
- Rep. Hern, Kevin [R-OK-1] (R-OK)
- Rep. Miller, Carol D. [R-WV-1] (R-WV)
- Rep. Miller, Max L. [R-OH-7] (R-OH)
- Rep. Schneider, Bradley Scott [D-IL-10] (D-IL)
- Rep. Sewell, Terri A. [D-AL-7] (D-AL)
Money behind the sponsor
Top reported contributors to Ron Estes’s campaign committee (2024 cycle) — who funds the bill’s sponsor, not a claim about this bill. Data from FEC.
- TRANSYSTEMS $21,650
- WATCO $13,200
- NULL $11,600
- BERGEN PAIN MANAGEMENT PC $9,900
- ASH BROKERAGE $7,061
Organizations whose employees gave the most — itemized individual contributions grouped by the donor’s reported employer (FEC Schedule A). Full finance for Ron Estes → · Outside spending →
Actions (2)
- Jan 31, 2025 Referred to the House Committee on Ways and Means. · house
- Jan 31, 2025 Introduced in House
Similar bills (6)
Bills with similar text or summary — includes reintroductions across Congresses. Ranked by semantic similarity of the bill text (computed locally); a neutral discovery aid, not a claim the bills are duplicates.
Full text
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. <all>
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