Referred to the House Committee on Ways and Means.
Amends the Internal Revenue Code (section 957(c)) to exclude certain bona fide residents of the U.S. Virgin Islands from being treated as United States persons for purposes of certain inclusions in gross income related to corporations organized under Virgin Islands law. The exclusion applies when a dividend received by the resident would be treated as Virgin Islands-source income under section 934(b)(1).
Liberals worry about anti-deferral erosion and revenue loss
Relative to its intended legislative type, this bill functions as a narrowly targeted substantive amendment to the Internal Revenue Code that is clear in purpose and specific in statutory drafting, integrates directly with existing provisions, and includes an effective date and conforming amendment.
Amends the Internal Revenue Code (section 957(c)) to exclude certain bona fide residents of the U.S. Virgin Islands from being treated as United States persons for purposes of certain inclusions in gross income related to corporations organized under Virgin Islands law.
The exclusion applies when a dividend received by the resident would be treated as Virgin Islands-source income under section 934(b)(1).
Conforming renumbering is included and the amendments apply to foreign-corporation taxable years beginning after December 31, 2024, and matching individual taxable years.
Narrow, technical bill increases chances, but fiscal implications, lack of offsets, and limited constituency reduce probability.
Relative to its intended legislative type, this bill functions as a narrowly targeted substantive amendment to the Internal Revenue Code that is clear in purpose and specific in statutory drafting, integrates directly with existing provisions, and includes an effective date and conforming amendment.
Liberals worry about anti-deferral erosion and revenue loss
These are examples from the analysis, not a ranked list of the most-affected groups.
Liberals worry about anti-deferral erosion and revenue loss
Likely to view the bill as a targeted correction addressing territorial tax fairness for Virgin Islands residents.
Supportive of parity for residents but cautious about weakening anti-deferral rules and potential revenue or abuse risks; would seek safeguards and transparency.
Any larger revenue or corporate avoidance impacts are speculative without a CBO score.
Sees the bill as a narrow, technical fix to align tax treatment of Virgin Islands residents with territorial sourcing rules.
Generally supportive if limited in scope and paired with clear residency tests and fiscal scoring.
Wants measurable safeguards and cost estimates before full backing.
Likely to favor the bill as reducing federal tax reach and promoting territorial autonomy for the Virgin Islands.
Views it as pro-growth, lowering taxes for residents, and simplifying compliance.
Generally supportive, though some may request residency verification to prevent abuse.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Narrow, technical bill increases chances, but fiscal implications, lack of offsets, and limited constituency reduce probability.
The bill has not accumulated any surfaced votes yet.
Liberals worry about anti-deferral erosion and revenue loss
Narrow, technical bill increases chances, but fiscal implications, lack of offsets, and limited constituency reduce probability.
Relative to its intended legislative type, this bill functions as a narrowly targeted substantive amendment to the Internal Revenue Code that is clear in purpose and specific in statutory drafting, integrates directly w…
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