Referred to the House Committee on Ways and Means.
This bill amends Internal Revenue Code rules affecting residents and source-of-income determinations for U.S. possessions (Guam, American Samoa, Northern Mariana Islands, Puerto Rico, U.S. Virgin Islands). It shortens the day-count/substantial presence threshold for bona fide residence, narrows when U.S.-source or effectively connected income is attributed to activities in the United States, and clarifies cross-references in section 865.
Progressives emphasize territorial equity and recovery benefits
Relative to its intended legislative type, this bill is a direct statutory amendment to the Internal Revenue Code designed to change residence and source rules for U.S. possessions.
This bill amends Internal Revenue Code rules affecting residents and source-of-income determinations for U.S. possessions (Guam, American Samoa, Northern Mariana Islands, Puerto Rico, U.S. Virgin Islands).
It shortens the day-count/substantial presence threshold for bona fide residence, narrows when U.S.-source or effectively connected income is attributed to activities in the United States, and clarifies cross-references in section 865.
The changes apply to taxable years beginning after December 31, 2024.
Technically narrow but fiscally-sensitive; lack of offsets and limited built-in compromises lower enactment odds unless attached to larger tax package.
Relative to its intended legislative type, this bill is a direct statutory amendment to the Internal Revenue Code designed to change residence and source rules for U.S. possessions. It specifies targeted code sections and an effective date but contains drafting defects and limited implementation, fiscal, and accountability detail.
Progressives emphasize territorial equity and recovery benefits
These are examples from the analysis, not a ranked list of the most-affected groups.
Progressives emphasize territorial equity and recovery benefits
Likely supportive as a targeted measure to strengthen territorial economies and tax sovereignty for possessions.
Would welcome relief that helps local residents and economies but will demand safeguards against corporate tax avoidance and revenue loss to social programs.
Cautiously favorable if accompanied by transparency, revenue estimates, and anti-abuse safeguards.
Views bill as a reasonable way to restore territorial tax rules but wants evidence it will not produce large deficits or loopholes.
Skeptical overall; may view as either an unnecessary tax carve-out or a helpful step toward territorial autonomy.
Main concerns are potential for complexity, loopholes, and reduced federal revenue without offsets.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Technically narrow but fiscally-sensitive; lack of offsets and limited built-in compromises lower enactment odds unless attached to larger tax package.
The bill has not accumulated any surfaced votes yet.
Progressives emphasize territorial equity and recovery benefits
Technically narrow but fiscally-sensitive; lack of offsets and limited built-in compromises lower enactment odds unless attached to larger…
Relative to its intended legislative type, this bill is a direct statutory amendment to the Internal Revenue Code designed to change residence and source rules for U.S. possessions. It specifies targeted code sections a…
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