Territorial Tax Parity and Fairness Act

Stacey E. Plaskett

Democrat · VI · Representative

Source: Congress.gov · FEC

No cosponsors on record. Bills can pass without cosponsors — this often means the sponsor introduced the bill alone, either because it's a messaging bill, a chairman's mark, or simply early in the legislative cycle.

Referred to the House Committee on Ways and Means.

2025-01-13

Source: Congress.gov

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.

Plain-English rewrite of the Congressional Research Service summary published on Congress.gov. Cached and reviewed.

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