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H.R. 363 119th Congress House

Territorial Economic Recovery Act

Official title: To amend the Internal Revenue Code of 1986 to exclude certain amounts from the tested income of controlled foreign corporations, and for other purposes.

Introduced: January 13, 2025 Introduced by: Stacey E. Plaskett Democratic · Virgin Islands See on congress.gov
Taxation American SamoaGuamIncome tax exclusionNorthern Mariana Islands
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Puerto RicoTaxation of foreign incomeU.S. territories and protectoratesVirgin Islands
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 Everywhere this bill has been 2 steps
Introduced
In committee
Reported out
Passed House
Passed Senate
To President
Became law
Jan 13, 2025
Referred to the House Committee on Ways and Means.
Jan 13, 2025
Introduced in House
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What's happening now January 13, 2025

Referred to the House Committee on Ways and Means.

 Plain-English summary Congressional Research Service

Territorial Economic Recovery Act

This bill excludes the income of certain controlled foreign corporations in U.S. territories from the calculation of global intangible low-taxed income (GILTI) for federal tax purposes.

Under current law, a U.S. shareholder of a controlled foreign corporation is required to include in gross income the GILTI of the shareholder. The calculation of GILTI is based, in part, on the controlled foreign corporation’s tested income (the controlled foreign corporation’s gross income less certain exclusions).

Under the bill, the income from a qualified possession corporation that is effectively connected with an active trade or business within a U.S. territory (Puerto Rico, U.S. Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands) is excluded from gross income for purposes of calculating a controlled foreign corporation’s tested income.

The bill defines a qualified possession corporation as any controlled foreign corporation if, for a three-year period ending in the prior tax year (or for the existence of the controlled foreign corporation if less than three years) (1) 80% or more of the controlled foreign corporation’s gross income was derived from a U.S. territory, and (2) 75% or more of the controlled foreign corporation’s gross income was effectively connected to the active conduct of a trade or business within a U.S. territory.

 Bill text 1 version

Source documents hosted by congress.gov.

 Committees of jurisdiction 1
 Lobbying activity 3

Registered lobbyists who named this bill in their disclosure filings. Source: federal Lobbying Disclosure Act filings.

  • CERTIFIED KERNEL TECH LLC
    for CERTIFIED KERNEL TECH LLC · New York · 3rd Quarter 2026 (July 1 - Sep 30)
  • CENCORA, INC.
    for CENCORA, INC. · District of Columbia · 2nd Quarter 2026 (Apr 1 - June 30)
  • CENCORA, INC.
    for CENCORA, INC. · District of Columbia · 1st Quarter 2026 (Jan 1 - Mar 31)

Bodies those filers lobbied

A filing lists the bills it worked on and the parts of government it contacted in separate sections, so these are the bodies those filers named anywhere in the filing, not a per-bill breakdown.

Cite this page click to expand
APA
U.S. Congress. (2026). H.R. 363: Territorial Economic Recovery Act. 119th Congress. Open America. https://openamerica.io/bill/119-HR-363/
MLA
"H.R. 363: Territorial Economic Recovery Act." 119th Congress, 2026, Open America, https://openamerica.io/bill/119-HR-363/.
Bluebook (legal)
H.R. 363, 119th Cong. (2026), https://openamerica.io/bill/119-HR-363/.
Markdown link
[H.R. 363: Territorial Economic Recovery Act](https://openamerica.io/bill/119-HR-363/)
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