H.R. 858 (119th)Bill Overview

REVIVE VI Act

Taxation|Taxation
Sponsor
Cosponsors
Support
Republican
Introduced
Jan 31, 2025
Discussions
Bill Text
Current stageCommittee

Referred to the House Committee on Ways and Means.

Introduced
Committee
Floor
President
Law
Congressional Activities
01 · The brief
Plain-English summaryWhat this bill actually does

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.

Why people may split

Progressives stress worker protections and revenue offsets.

Watch point

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.

Passage45/100

Moderately plausible as a narrow, territory‑boosting tax carve‑out but constrained by fiscal scrutiny and Senate hurdles.

CredibilityAligned

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.

Contention30/100

Progressives stress worker protections and revenue offsets.

02 · What it does

Who stands to gain, and who may push back.

Likely benefits vs burdens50% / 50%
Local governmentsFederal agencies · Taxpayers

These are examples from the analysis, not a ranked list of the most-affected groups.

Likely helped
  • 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.
Likely burdened
  • 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…
03 · Why people split

Why the argument around this bill splits.

Progressives stress worker protections and revenue offsets.
Progressive60%

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.

Split reaction
Centrist70%

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.

Leans supportive
Conservative85%

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.

Leans supportive
04 · Can it pass?

The path through Congress.

Introduced

Reached or meaningfully advanced

Committee

Reached or meaningfully advanced

Floor

Still ahead

President

Still ahead

Law

Still ahead

Passage likelihood45/100

Moderately plausible as a narrow, territory‑boosting tax carve‑out but constrained by fiscal scrutiny and Senate hurdles.

Scope and complexity
52%
Scopemoderate
52%
Complexitymedium
Why this could stall
  • No Congressional Budget Office/JCT score provided
  • Unknown level of congressional support or opposition
05 · Recent votes

Recent votes on the bill.

No vote history yet

The bill has not accumulated any surfaced votes yet.

06 · Go deeper

Go deeper than the headline read.

Included on this page

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.

Unlocked analysis

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.

Perspective breakdownsPassage barriersLegislative design reviewStakeholder impact map
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