I
119THCONGRESS
1
STSESSION H. R. 368
To amend the Internal Revenue Code of 1986 to provide that certain bona
fide residents of the Virgin Islands who are shareholders of corporations
organized under the laws of the Virgin Islands are not treated as United
States persons for purposes of determining certain inclusions in gross
income with respect to such corporations.
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 provide
that certain bona fide residents of the Virgin Islands
who are shareholders of corporations organized under
the laws of the Virgin Islands are not treated as United
States persons for purposes of determining certain inclu-
sions in gross income with respect to such corporations.
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
and Fairness Act’’. 5
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•HR 368 IH
SEC. 2. CERTAIN BONA FIDE RESIDENTS OF VIRGIN IS-1
LANDS. 2
(a) I
NGENERAL.—Section 957(c) of the Internal 3
Revenue Code of 1986 is amended by striking ‘‘and’’ at 4
the end of paragraph (1), by redesignating paragraph (2) 5
as paragraph (3), and by inserting after paragraph (1) 6
the following new paragraph: 7
‘‘(2) with respect to a corporation organized 8
under the laws of the Virgin Islands, such term does 9
not include an individual who is a bona fide resident 10
of the Virgin Islands, if a dividend received by such 11
individual during the taxable year from such cor-12
poration would, for purposes of section 934(b)(1), be 13
treated as income derived from sources within the 14
Virgin Islands, and’’. 15
(b) C
ONFORMINGAMENDMENT.—Section 957(c) of 16
such Code is amended by striking ‘‘paragraph (2)’’ in the 17
last sentence and inserting ‘‘paragraph (3)’’. 18
(c) E
FFECTIVEDATE.—The amendments made by 19
this section shall apply to taxable years of foreign corpora-20
tions beginning after December 31, 2024, and taxable 21
years of individuals within which or with which such tax-22
able years of foreign corporations end. 23
Æ
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