| 1 | 1 | | I |
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| 2 | 2 | | 119THCONGRESS |
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| 3 | 3 | | 1 |
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| 4 | 4 | | STSESSION H. R. 368 |
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| 5 | 5 | | To amend the Internal Revenue Code of 1986 to provide that certain bona |
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| 6 | 6 | | fide residents of the Virgin Islands who are shareholders of corporations |
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| 7 | 7 | | organized under the laws of the Virgin Islands are not treated as United |
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| 8 | 8 | | States persons for purposes of determining certain inclusions in gross |
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| 9 | 9 | | income with respect to such corporations. |
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| 10 | 10 | | IN THE HOUSE OF REPRESENTATIVES |
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| 11 | 11 | | JANUARY13, 2025 |
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| 12 | 12 | | Ms. P |
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| 13 | 13 | | LASKETTintroduced the following bill; which was referred to the |
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| 14 | 14 | | Committee on Ways and Means |
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| 15 | 15 | | A BILL |
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| 16 | 16 | | To amend the Internal Revenue Code of 1986 to provide |
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| 17 | 17 | | that certain bona fide residents of the Virgin Islands |
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| 18 | 18 | | who are shareholders of corporations organized under |
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| 19 | 19 | | the laws of the Virgin Islands are not treated as United |
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| 20 | 20 | | States persons for purposes of determining certain inclu- |
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| 21 | 21 | | sions in gross income with respect to such corporations. |
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| 22 | 22 | | Be it enacted by the Senate and House of Representa-1 |
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| 23 | 23 | | tives of the United States of America in Congress assembled, 2 |
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| 24 | 24 | | SECTION 1. SHORT TITLE. 3 |
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| 25 | 25 | | This Act may be cited as the ‘‘Territorial Tax Parity 4 |
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| 26 | 26 | | and Fairness Act’’. 5 |
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| 27 | 27 | | VerDate Sep 11 2014 18:06 Feb 05, 2025 Jkt 059200 PO 00000 Frm 00001 Fmt 6652 Sfmt 6201 E:\BILLS\H368.IH H368 |
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| 28 | 28 | | ssavage on LAPJG3WLY3PROD with BILLS 2 |
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| 29 | 29 | | •HR 368 IH |
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| 30 | 30 | | SEC. 2. CERTAIN BONA FIDE RESIDENTS OF VIRGIN IS-1 |
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| 31 | 31 | | LANDS. 2 |
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| 32 | 32 | | (a) I |
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| 33 | 33 | | NGENERAL.—Section 957(c) of the Internal 3 |
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| 34 | 34 | | Revenue Code of 1986 is amended by striking ‘‘and’’ at 4 |
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| 35 | 35 | | the end of paragraph (1), by redesignating paragraph (2) 5 |
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| 36 | 36 | | as paragraph (3), and by inserting after paragraph (1) 6 |
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| 37 | 37 | | the following new paragraph: 7 |
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| 38 | 38 | | ‘‘(2) with respect to a corporation organized 8 |
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| 39 | 39 | | under the laws of the Virgin Islands, such term does 9 |
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| 40 | 40 | | not include an individual who is a bona fide resident 10 |
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| 41 | 41 | | of the Virgin Islands, if a dividend received by such 11 |
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| 42 | 42 | | individual during the taxable year from such cor-12 |
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| 43 | 43 | | poration would, for purposes of section 934(b)(1), be 13 |
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| 44 | 44 | | treated as income derived from sources within the 14 |
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| 45 | 45 | | Virgin Islands, and’’. 15 |
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| 46 | 46 | | (b) C |
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| 47 | 47 | | ONFORMINGAMENDMENT.—Section 957(c) of 16 |
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| 48 | 48 | | such Code is amended by striking ‘‘paragraph (2)’’ in the 17 |
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| 49 | 49 | | last sentence and inserting ‘‘paragraph (3)’’. 18 |
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| 50 | 50 | | (c) E |
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| 51 | 51 | | FFECTIVEDATE.—The amendments made by 19 |
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| 52 | 52 | | this section shall apply to taxable years of foreign corpora-20 |
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| 53 | 53 | | tions beginning after December 31, 2024, and taxable 21 |
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| 54 | 54 | | years of individuals within which or with which such tax-22 |
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| 55 | 55 | | able years of foreign corporations end. 23 |
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| 56 | 56 | | Æ |
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| 57 | 57 | | VerDate Sep 11 2014 18:06 Feb 05, 2025 Jkt 059200 PO 00000 Frm 00002 Fmt 6652 Sfmt 6301 E:\BILLS\H368.IH H368 |
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| 58 | 58 | | ssavage on LAPJG3WLY3PROD with BILLS |
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