Only the left has signed this so far (Bill Ranking)
H.R. 364 · 119th Congress (2025-2026)
1 member · Left 1 · Center 0 · Right 0 (Bill Ranking)
| Sponsor | Del. Plaskett, Stacey E. (D-VI) (Introduced 01/13/2025) |
|---|---|
| Sponsor Voting Record | Lean left · DW-NOMINATE -0.47 · measured from every roll-call vote this member has cast (voteview.com) (Sponsor Ranking) |
| Support |
LLLCLRR support across the spectrum: 1 member signed on (Bill Ranking) this bill: sponsor + current cosponsors, each once |
| Committees | House - Ways and Means Committee |
| Latest Action | 01/13/2025 Referred to the House Committee on Ways and Means. |
| Roll Call Votes | There have been no roll call votes |
| Source | view on congress.gov → |
Introduced in House (01/13/2025)
Territorial Tax Equity and Economic Growth Act of 2025
This bill lowers the residency requirements and modifies the income sourcing rules related to taxation of income from U.S. territories.
Currently, bona fide residents of a U.S. territory may exclude income sourced to the territory in calculating U.S. federal income tax. A bona fide resident of a territory is a person that, in part, is present in the territory for at least 183 days in a tax year. Income is sourced to a U.S. territory if it is not U.S.-sourced income or effectively connected with a U.S. trade or business.
This bill
Currently, income from certain personal property sales from a fixed place of business in a U.S. territory by a U.S. resident may be U.S.-sourced income unless an income tax of at least 10% is paid to the U.S. territory. The Internal Revenue Service (IRS) may limit the 10% tax payment requirement related to income from personal property sales in Guam, American Samoa, the Northern Mariana Islands, and Puerto Rico. This bill expands the IRS’s authority to include limiting the tax requirement for personal property sales in the Virgin Islands.
119 HR 364 IH: Territorial Tax Equity and Economic Growth Act of 2025 U.S. House of Representatives 2025-01-13 text/xml EN Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain. I119th CONGRESS1st SessionH. R. 364IN THE HOUSE OF REPRESENTATIVESJanuary 13, 2025Ms. Plaskett introduced the following bill; which was referred to the Committee on Ways and MeansA BILLTo amend the Internal Revenue Code of 1986 to modify the residence and source rules to provide for economic recovery in the possessions of the United States.1.Short titleThis Act may be cited as the Territorial Tax Equity and Economic Growth Act of 2025.2.Modification to residence and source rules involving possessions(a)Bona fide residentSection 937(a) of the Internal Revenue Code of 1986 is amended—(1)by striking the last sentence, and(2)by amending paragraph (1) to read as follows:(1)who has a substantial presence (determined under the principles of section 7701(b)(3)(A) (applied by substituting 122 days for 31 days in clause (i) thereof) without regard to sections 7701(b)(3)(B), (C), and (D)) during the taxable year in Guam, American Samoa, the Northern Mariana Islands, Puerto Rico, or the Virgin Islands, as the case may be, and.(b)Source rulesSection 937(b) of such Code is amended—(1)in paragraph (1), by striking and at the end,(2)in paragraph (2), by striking the period at the end and inserting , but only to the extent such income is attributable to an office or fixed place of business within the United States (determined under the rules of section 864(c)(5)),, and(3)by adding at the end the following new paragraphs:(3)for purposes of paragraph (1), the principles of section 864(c)(2), rather than rules similar to the rules in section 864(c)(4), shall apply for purposes of determining whether income from sources without a possession specified in subsection (a)(1) is effectively connected with the conduct of a trade or business within such possession, and(4)for purposes of paragraph (2), income from activities within the United States which are of a preparatory or auxiliary character shall not be treated as income from sources within the United States or as effectively connected with the conduct of a trade or business within the United States..(c)Source rules for personal property salesSection 865(j)(3) of such Code is amended by inserting , 932, after
931.(d)Effective dateThe amendments made by this section shall apply to taxable years beginning after December 31, 2024.
The bill's own words, from our database (synced from the GPO BILLS XML); paragraph breaks added at the bill's section boundaries, nothing else changed.
| Date | Chamber | All Actions |
|---|---|---|
| 01/13/2025 | Library of Congress | Introduced in House |
| 01/13/2025 | Library of Congress | Introduced in House |
| 01/13/2025 | House floor actions | Referred to the House Committee on Ways and Means. |
| Title Type | Title |
|---|---|
| Display Title | Territorial Tax Equity and Economic Growth Act of 2025 |
| Short Title(s) as Introduced | Territorial Tax Equity and Economic Growth Act of 2025 |
| Official Title as Introduced | To amend the Internal Revenue Code of 1986 to modify the residence and source rules to provide for economic recovery in the possessions of the United States. |
There are no amendments to this bill.
There are no cosponsors of this bill.
| Committee | Activity |
|---|---|
| House - Ways and Means Committee | 01/13/2025 Referred To |
No related bill information was received for H.R. 364.
Policy Area: Taxation
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