- Local governmentsMay encourage firms to locate service jobs in the Virgin Islands, potentially increasing local employment.
- Local governmentsCould boost Virgin Islands economic activity and investment by making local service income more tax-competitive.
- Potential benefitReduces effective U.S. tax on qualified Virgin Islands service income for eligible shareholders.
REVIVE VI Act
Referred to the House Committee on Ways and Means.
This bill amends Internal Revenue Code section 951A (GILTI) to exclude certain income earned from services performed in the U.S. Virgin Islands by Virgin Islands corporations from GILTI calculations. It defines "qualified Virgin Islands services income," limits which U.S. shareholders are covered, requires Treasury regulations to prevent abuse, and applies to foreign corporations' taxable years beginning after enactment.
Progressives stress worker protections and revenue offsets.
Relative to its intended legislative type, this bill is a narrowly targeted substantive amendment to the Internal Revenue Code that is reasonably well-specified in statutory terms.
This bill amends Internal Revenue Code section 951A (GILTI) to exclude certain income earned from services performed in the U.S. Virgin Islands by Virgin Islands corporations from GILTI calculations.
It defines "qualified Virgin Islands services income," limits which U.S. shareholders are covered, requires Treasury regulations to prevent abuse, and applies to foreign corporations' taxable years beginning after enactment.
Moderately plausible as a narrow, territory‑boosting tax carve‑out but constrained by fiscal scrutiny and Senate hurdles.
Relative to its intended legislative type, this bill is a narrowly targeted substantive amendment to the Internal Revenue Code that is reasonably well-specified in statutory terms. It defines the excluded category precisely, identifies affected taxpayers, sets an effective date, and delegates necessary regulatory authority.
Progressives stress worker protections and revenue offsets.
Who stands to gain, and who may push back.
These are examples from the analysis, not a ranked list of the most-affected groups.
- Federal agenciesCould reduce federal tax receipts by excluding specified Virgin Islands service income from GILTI taxation.
- Potential burdenMay create opportunities for profit shifting or tax planning to classify income as Virgin Islands services income.
- TaxpayersOffers preferential treatment to certain taxpayers, including pre-2024 closely held C corporations, creating uneven tax…
Why the argument around this bill splits.
Progressives stress worker protections and revenue offsets.
Mixed reaction: supports economic aid to U.S. territories and potential local job growth, but worries the provision primarily benefits shareholders and may reduce federal revenue.
Would seek stronger worker protections, transparency, and revenue offsets to ensure benefits reach local residents.
Generally favorable but cautious: the bill is a targeted territorial incentive that could spur investment, yet raises legitimate fiscal and anti-abuse questions.
Support likely contingent on clear Treasury regulations, measurable outcomes, and budgetary offsets or sunset/evaluation provisions.
Supportive: sees the bill as sensible tax relief to attract investment and jobs to the Virgin Islands.
Prefers market-driven growth and views territorial tax incentives as appropriate federal policy to spur private-sector activity.
The path through Congress.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Moderately plausible as a narrow, territory‑boosting tax carve‑out but constrained by fiscal scrutiny and Senate hurdles.
- No Congressional Budget Office/JCT score provided
- Unknown level of congressional support or opposition
Recent votes on the bill.
No vote history yet
The bill has not accumulated any surfaced votes yet.
Go deeper than the headline read.
Progressives stress worker protections and revenue offsets.
Moderately plausible as a narrow, territory‑boosting tax carve‑out but constrained by fiscal scrutiny and Senate hurdles.
Relative to its intended legislative type, this bill is a narrowly targeted substantive amendment to the Internal Revenue Code that is reasonably well-specified in statutory terms. It defines the excluded category preci…
Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.