Only the left has signed this so far (Bill Ranking)
H.R. 368 · 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 Parity and Fairness Act
This bill excepts individuals who are bona fide residents of the Virgin Islands from including in gross income for U.S. federal tax purposes subpart F income received from certain corporations if such income may be sourced to the Virgin Islands.
Under current law, a U.S. shareholder of a controlled foreign corporation generally is required to include in gross income their pro rata share of dividends, interest, rent, royalties, and certain other types of income of the controlled foreign corporation (collectively known as subpart F income). A U.S. shareholder is a U.S. person (citizen, resident, domestic partnership or corporation, trust, or estate) that owns a certain percentage of stock in the controlled foreign corporation.
However, under current law, the definition of a U.S. person does not include individuals who are bona fide residents of the U.S. territories of Puerto Rico, Guam, America Samoa, and the Northern Mariana Islands who receive subpart F income from controlled foreign corporations that meets certain requirements for being sourced to the territory or being connected to or derived from a trade or business in the territory.
This bill expands the exceptions from the definition of a U.S. person for purposes of the subpart F income tax rules, to include individuals who are bona fide residents of the Virgin Islands and receive subpart F income from a controlled foreign corporation organized under the laws of the Virgin Islands if the subpart F income may be sourced to the Virgin Islands.
119 HR 368 IH: Territorial Tax Parity and Fairness Act 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. 368IN 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 provide that certain bona fide residents of the Virgin Islands who are shareholders of corporations organized under the laws of the Virgin Islands are not treated as United States persons for purposes of determining certain inclusions in gross income with respect to such corporations.1.Short titleThis Act may be cited as the Territorial Tax Parity and Fairness Act.2.Certain bona fide residents of Virgin Islands(a)In generalSection 957(c) of the Internal Revenue Code of 1986 is amended by striking and at the end of paragraph (1), by redesignating paragraph (2) as paragraph (3), and by inserting after paragraph (1) the following new paragraph:(2)with respect to a corporation organized under the laws of the Virgin Islands, such term does not include an individual who is a bona fide resident of the Virgin Islands, if a dividend received by such individual during the taxable year from such corporation would, for purposes of section 934(b)(1), be treated as income derived from sources within the Virgin Islands, and.(b)Conforming amendmentSection 957(c) of such Code is amended by striking paragraph (2) in the last sentence and inserting paragraph (3).(c)Effective dateThe amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2024, and taxable years of individuals within which or with which such taxable years of foreign corporations end.
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 Parity and Fairness Act |
| Short Title(s) as Introduced | Territorial Tax Parity and Fairness Act |
| Official Title as Introduced | To amend the Internal Revenue Code of 1986 to provide that certain bona fide residents of the Virgin Islands who are shareholders of corporations organized under the laws of the Virgin Islands are not treated as United States persons for purposes of determining certain inclusions in gross income with respect to such corporations. |
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. 368.
Policy Area: Taxation
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