I
119THCONGRESS
1
STSESSION H. R. 365
To amend the Internal Revenue Code of 1986 to modify the residence and
source rules to provide for economic recovery in the possessions of the
United States.
IN THE HOUSE OF REPRESENTATIVES
JANUARY13, 2025
Ms. P
LASKETTintroduced the following bill; which was referred to the
Committee on Ways and Means
A BILL
To amend the Internal Revenue Code of 1986 to modify
the residence and source rules to provide for economic
recovery in the possessions of the United States.
Be it enacted by the Senate and House of Representa-1
tives of the United States of America in Congress assembled, 2
SECTION 1. SHORT TITLE. 3
This Act may be cited as the ‘‘Territorial Tax Parity 4
Act of 2025’’. 5
SEC. 2. MODIFICATION TO SOURCE RULES INVOLVING POS-6
SESSIONS. 7
(a) I
NGENERAL.—Section 937(b)(2) of the Internal 8
Revenue Code of 1986 is amended by inserting ‘‘, but only 9
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•HR 365 IH
to the extent such income is attributable to an office or 1
fixed place of business within the United States (deter-2
mined under the rules of section 864(c)(5))’’ before the 3
period at the end. 4
(b) S
OURCERULES FOR PERSONALPROPERTY 5
S
ALES.—Section 865(j)(3) of such Code is amended by 6
inserting ‘‘, 932,’’ after ‘‘931’’. 7
(c) E
FFECTIVEDATE.—The amendments made by 8
this section shall apply to taxable years beginning after 9
December 31, 2024. 10
Æ
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