I
119THCONGRESS
1
STSESSION 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
JANUARY31, 2025
Mr. E
STES(for himself, Ms. PLASKETT, Mr. HERNof Oklahoma, Ms. SE-
WELL, 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 cer-
tain income derived from services performed in the Vir-
gin Islands.
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 ‘‘Restore Economic Vi-4
tality and Investment in the Virgin Islands Act’’ or the 5
‘‘REVIVE VI Act’’. 6
VerDate Sep 11 2014 02:10 Feb 27, 2025 Jkt 059200 PO 00000 Frm 00001 Fmt 6652 Sfmt 6201 E:\BILLS\H858.IH H858
kjohnson on DSK7ZCZBW3PROD with $$_JOB 2
•HR 858 IH
SEC. 2. GLOBAL INTANGIBLE LOW-TAXED INCOME DETER-1
MINED WITHOUT REGARD TO CERTAIN IN-2
COME DERIVED FROM SERVICES PER-3
FORMED IN THE VIRGIN ISLANDS. 4
(a) I
NGENERAL.—Section 951A(c)(2)(A)(i) of the 5
Internal Revenue Code of 1986 is amended by striking 6
‘‘and’’ at the end of subclause (IV), by striking the period 7
at the end of subclause (V) and inserting ‘‘, and’’, and 8
by adding at the end the following new subclause: 9
‘‘(VI) in the case of any specified 10
United States shareholder, any quali-11
fied Virgin Islands services income.’’. 12
(b) D
EFINITIONS AND SPECIALRULES.—Section 13
951A(c)(2) of such Code is amended by adding at the end 14
the following new subparagraph: 15
‘‘(C) P
ROVISIONS RELATED TO QUALIFIED 16
VIRGIN ISLANDS SERVICES INCOME .—For pur-17
poses of subparagraph (A)(i)(VI)— 18
‘‘(i) Q
UALIFIED VIRGIN ISLANDS 19
SERVICES INCOME.—The term ‘qualified 20
Virgin Islands services income’ means any 21
gross income which satisfies all of the fol-22
lowing requirements: 23
‘‘(I) Such gross income is com-24
pensation for labor or personal serv-25
ices (within the meaning of section 26
VerDate Sep 11 2014 02:10 Feb 27, 2025 Jkt 059200 PO 00000 Frm 00002 Fmt 6652 Sfmt 6201 E:\BILLS\H858.IH H858
kjohnson on DSK7ZCZBW3PROD with $$_JOB 3
•HR 858 IH
862(a)(3)) performed in the Virgin Is-1
lands by a corporation formed under 2
the laws of the Virgin Islands. 3
‘‘(II) Such gross income is attrib-4
utable to services performed from 5
within the Virgin Islands by individ-6
uals for the benefit of such corpora-7
tion. 8
‘‘(III) Such gross income is effec-9
tively connected with the conduct of a 10
trade or business within the Virgin Is-11
lands. 12
‘‘(ii) S
PECIFIED UNITED STATES 13
SHAREHOLDER.—The term ‘specified 14
United States shareholder’ means any 15
United States shareholder which is— 16
‘‘(I) an individual, trust, or es-17
tate, or 18
‘‘(II) a closely held C corporation 19
(as defined in section 469(j)(1)) if 20
such corporation acquired its direct or 21
indirect equity interest in the foreign 22
corporation which derived the quali-23
fied Virgin Islands services income be-24
fore December 31, 2023. 25
VerDate Sep 11 2014 02:10 Feb 27, 2025 Jkt 059200 PO 00000 Frm 00003 Fmt 6652 Sfmt 6201 E:\BILLS\H858.IH H858
kjohnson on DSK7ZCZBW3PROD with $$_JOB 4
•HR 858 IH
‘‘(iii) REGULATIONS.—The Secretary 1
shall prescribe such regulations or other 2
guidance as may be necessary or appro-3
priate to carry out this subparagraph and 4
subparagraph (A)(i)(VI), including regula-5
tions or other guidance to prevent the 6
abuse of such subparagraphs.’’. 7
(c) E
FFECTIVEDATE.—The amendments made by 8
this section shall apply to taxable years of foreign corpora-9
tions beginning after the date of the enactment of this 10
Act, and to taxable years of United States shareholders 11
with or within which such taxable years of foreign corpora-12
tions end. 13
Æ
VerDate Sep 11 2014 02:10 Feb 27, 2025 Jkt 059200 PO 00000 Frm 00004 Fmt 6652 Sfmt 6301 E:\BILLS\H858.IH H858
kjohnson on DSK7ZCZBW3PROD with $$_JOB