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H.R. 368 119th Congress House

Territorial Tax Parity and Fairness Act

Official title: 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 und… Show full official titleShow less

Official title: 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.

Introduced: January 13, 2025 Introduced by: Stacey E. Plaskett Democratic · Virgin Islands See on congress.gov
Taxation Income tax ratesTax administration and collection, taxpayersU.S. territories and protectoratesVirgin Islands
 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 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.

 Bill text 1 version

Source documents hosted by congress.gov.

 Committees of jurisdiction 1
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APA
U.S. Congress. (2026). H.R. 368: Territorial Tax Parity and Fairness Act. 119th Congress. Open America. https://openamerica.io/bill/119-HR-368/
MLA
"H.R. 368: Territorial Tax Parity and Fairness Act." 119th Congress, 2026, Open America, https://openamerica.io/bill/119-HR-368/.
Bluebook (legal)
H.R. 368, 119th Cong. (2026), https://openamerica.io/bill/119-HR-368/.
Markdown link
[H.R. 368: Territorial Tax Parity and Fairness Act](https://openamerica.io/bill/119-HR-368/)
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