Comparison of provisions of H.R. 7093 (income tax rate on Virgin Islands source income) : as passed by the House of Representatives.
Joint Committee on Taxation December 18, 1982 JCX-54-82 Comparison of Provisions of H.R. 7093 (Income Tax Rate on Virgin Islands Source Income) As Passed by the House of Representatives Tax Title Present law The Virgin Islands Government contends that payments of passive investment income by V.I. persons to U.S. persons are subject to a 30-percent tax (on the gross amount of the payment) and a corresponding withholding obligation. Certain U.S. recipients of such income contend that such payments are subject to neither tax nor withholding. (Similar payments to foreign persons are clearly subject to the tax and the withholding obligation.) Senate position The Senate language (which is identical to the original House language) provides that the rate of V.I. tax on payments of passive investment income from V.I. persons to U.S. persons shall not exceed 10 percent. This treatment would apply to dividend payments out of earnings and profits accumulated in taxable years beginning on or after the date of enactment. …
Download the original document · Plain text (TXT) · Browse the archive · How this archive works
Original source: https://archive.org/download/comparisonofprov5482unit/comparisonofprov5482unit.pdf
SHA-256 7512f70c2c7d157c2d94a48d6e7bf897303a0f5cac34a8e0da39ff1914a1cd99
Re-using this document
mixed and recorded per item: public domain by age or as a US government work for what was taken; controlled-digital-lending and restrictively licensed items EXCLUDED, each listed with its reason
Our description, tagging, arrangement, extracted text and machine transcripts are released under CC0 1.0. We assert nothing about the document itself.
Archive identifier LF-7512f70c2c7d
Document text
Joint Committee on Taxation December 18, 1982 JCX-54-82 Comparison of Provisions of H.R. 7093 (Income Tax Rate on Virgin Islands Source Income) As Passed by the House of Representatives Tax Title Present law The Virgin Islands Government contends that payments of passive investment income by V.I. persons to U.S. persons are subject to a 30-percent tax (on the gross amount of the payment) and a corresponding withholding obligation. Certain U.S. recipients of such income contend that such payments are subject to neither tax nor withholding. (Similar payments to foreign persons are clearly subject to the tax and the withholding obligation.) Senate position The Senate language (which is identical to the original House language) provides that the rate of V.I. tax on payments of passive investment income from V.I. persons to U.S. persons shall not exceed 10 percent. This treatment would apply to dividend payments out of earnings and profits accumulated in taxable years beginning on or after the date of enactment. The Government of the Virgin Islands would be able to reduce this 10-percent maximum rate in its discretion. The withholding obligation of the payor would in every case correspond to the substantive tax liability of the recipient. Payments to foreign persons would continue to be subject to the 30-percent tax and corresponding withholding. House amendment in disagreement The House amendment follows the Senate position, but makes two technical changes. First, the House amendment makes it clear that Congress is taking neither side in the current dispute between U.S. persons and the V.I. Government by striking references to "reductions" in tax. Second, the House amendment makes it clear that the Virgin Islands will be able to impose and require withholding of a tax of up to 10 percent on payments of passive income to U.S. persons. Conference agreement