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H.R. 364 119th Congress House

Territorial Tax Equity and Economic Growth Act of 2025

Official title: 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.

Introduced: January 13, 2025 Introduced by: Stacey E. Plaskett Democratic · Virgin Islands See on congress.gov
Taxation American SamoaCaribbean areaGuamNorthern Mariana Islands
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Puerto RicoTax administration and collection, taxpayersTaxation 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 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

  • reduces the presence requirement to 122 days,
  • specifies that income is U.S.-sourced income or effectively connected to a U.S. trade or business only if attributable to an office or fixed place of business in the United States, and
  • specifies that income from U.S.-based activities that are preparatory or auxiliary may not be considered U.S.-sourced income.

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.

 Bill text 1 version

Source documents hosted by congress.gov.

 Committees of jurisdiction 1
 Lobbying activity 2

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

Bodies those filers lobbied

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APA
U.S. Congress. (2026). H.R. 364: Territorial Tax Equity and Economic Growth Act of 2025. 119th Congress. Open America. https://openamerica.io/bill/119-HR-364/
MLA
"H.R. 364: Territorial Tax Equity and Economic Growth Act of 2025." 119th Congress, 2026, Open America, https://openamerica.io/bill/119-HR-364/.
Bluebook (legal)
H.R. 364, 119th Cong. (2026), https://openamerica.io/bill/119-HR-364/.
Markdown link
[H.R. 364: Territorial Tax Equity and Economic Growth Act of 2025](https://openamerica.io/bill/119-HR-364/)
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