What This Bill Does · Plain English
Summary · Congress.gov
Restore Economic Vitality and Investment in the Virgin Islands Act or the REVIVE VI Act This bill allows certain U.S. shareholders of a controlled foreign corporation to exclude qualified Virgin Islands service income from the calculation of global intangible low-taxed income (GILTI) for federal tax purposes. It also requires the Internal Revenue Service (IRS) to issue guidance on the exclusion. (Some limitations apply.) Under current law, U.S. shareholders that own 10% or more of a controlled foreign corporation are required to include in gross income the GILTI of the controlled foreign corporation. The calculation of GILTI is based, in part, on the controlled foreign corporation’s tested income (the controlled foreign corporation’s gross income excluding certain types of income and dividends). Under the bill, specified U.S. shareholders (individuals, trusts, estates, and certain closely-held C corporations) may exclude qualified Virgin Islands service income from a controlled foreign corporation’s gross income for purposes of calculating the controlled foreign corporation’s tested income. The bill defines qualified Virgin Islands service income as gross income that is compensation for labor or personal services performed in the Virgin Islands by a corporation formed under Virgin Islands laws, attributable to services performed in the Virgin Islands by individuals for the benefit of such corporation, and effectively connected with the conduct of a trade or business in the Vi
Action Timeline
2025-01-31
Referred to the House Committee on Ways and Means.
2025-01-31
Introduced in House
2025-01-31
Introduced in House
Frequently Asked Questions
Did HR.858 pass?
HR.858 is still alive. Current stage: COMMITTEE. Pass likelihood: 31%.
What does HR.858 do?
Restore Economic Vitality and Investment in the Virgin Islands Act or the REVIVE VI Act This bill allows certain U.S. shareholders of a controlled foreign corporation to exclude qualified Virgin Islands service income from the calculation of global intangible low-taxed income (GILTI) for federal tax purposes. It also requires the Internal Revenue Service (IRS) to issue guidance on the exclusion. (Some limitations apply.) Under current law, U.S. shareholders that own 10% or more of a controlled foreign corporation are required to include in gross income the GILTI of the controlled foreign corpo…
Who sponsored HR.858?
HR.858 was sponsored by Ron Estes (R-Kansas).
Full Bill Text
119 HR 858 IH: Restore Economic Vitality and Investment in the Virgin Islands Act U.S. House of Representatives 2025-01-31 text/xml EN Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain. I 119th CONGRESS 1st Session H. R. 858 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. 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 . 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.
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