119TH CONGRESS
I 119TH CONGRESS 1ST SESSION 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 JANUARY 13, 2025 Ms. PLASKETT 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 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’’. …
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I 119TH CONGRESS 1ST SESSION 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 JANUARY 13, 2025 Ms. PLASKETT 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 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 VerDate Sep 11 2014 18:06 Feb 05, 2025 Jkt 059200 PO 00000 Frm 00001 Fmt 6652 Sfmt 6201 E:\BILLS\H368.IH H368 ssavage on LAPJG3WLY3PROD with BILLS 2 •HR 368 IH SEC. 2. CERTAIN BONA FIDE RESIDENTS OF VIRGIN IS- 1 LANDS. 2 (a) IN GENERAL.—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) CONFORMING AMENDMENT.—Section 957(c) of 16 such Code is amended by striking ‘‘paragraph (2)’’ in the 17 last sentence and inserting ‘‘paragraph (3)’’. 18 (c) EFFECTIVE DATE.—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 VerDate Sep 11 2014 18:06 Feb 05, 2025 Jkt 059200 PO 00000 Frm 00002 Fmt 6652 Sfmt 6301 E:\BILLS\H368.IH H368 ssavage on LAPJG3WLY3PROD with BILLS