Skip to main content
H.R. 858 119th Congress House

REVIVE VI Act

Official title: To amend the Internal Revenue Code of 1986 to determine global intangible low-taxed income without regard to certain income derived from services performed in the Virgin Islands.

Introduced: January 31, 2025 Introduced by: Ron Estes Republican · Kansas See on congress.gov
 Everywhere this bill has been 2 steps
Introduced
In committee
Reported out
Passed House
Passed Senate
To President
Became law
Jan 31, 2025
Referred to the House Committee on Ways and Means.
Jan 31, 2025
Introduced in House
 Ask about this bill AI · grounded in the bill text

Have a question about what this bill does? Ask in plain English; the answer is drawn from the bill's actual text and official record, and it'll tell you when something isn't in the text rather than guess.

AI answers can be imperfect; always confirm against the full bill text.

What's happening now January 31, 2025

Referred to the House Committee on Ways and Means.

 Plain-English summary Congressional Research Service

Restore Economic Vitality and Investment in the Virgin Islands Act or the REVIVE VI Act

This bill allows certain U.S. shareholders of a controlled foreign corporation to exclude qualified Virgin Islands service income from the calculation of global intangible low-taxed income (GILTI) for federal tax purposes. It also requires the Internal Revenue Service (IRS) to issue guidance on the exclusion. (Some limitations apply.)

Under current law, U.S. shareholders that own 10% or more of a controlled foreign corporation are required to include in gross income the GILTI of the controlled foreign corporation. The calculation of GILTI is based, in part, on the controlled foreign corporation’s tested income (the controlled foreign corporation’s gross income excluding certain types of income and dividends).

Under the bill, specified U.S. shareholders (individuals, trusts, estates, and certain closely-held C corporations) may exclude qualified Virgin Islands service income from a controlled foreign corporation’s gross income for purposes of calculating the controlled foreign corporation’s tested income.

The bill defines qualified Virgin Islands service income as gross income that is

  • compensation for labor or personal services performed in the Virgin Islands by a corporation formed under Virgin Islands laws,
  • attributable to services performed in the Virgin Islands by individuals for the benefit of such corporation, and
  • effectively connected with the conduct of a trade or business in the Virgin Islands.

Finally, the bill requires the IRS to issue guidance on the exclusion of qualified Virgin Island service income from the GILTI calculation.

 Related & companion bills 1
 Bill text 1 version

Source documents hosted by congress.gov.

 Committees of jurisdiction 1
Cite this page click to expand
APA
U.S. Congress. (2026). H.R. 858: REVIVE VI Act. 119th Congress. Open America. https://openamerica.io/bill/119-HR-858/
MLA
"H.R. 858: REVIVE VI Act." 119th Congress, 2026, Open America, https://openamerica.io/bill/119-HR-858/.
Bluebook (legal)
H.R. 858, 119th Cong. (2026), https://openamerica.io/bill/119-HR-858/.
Markdown link
[H.R. 858: REVIVE VI Act](https://openamerica.io/bill/119-HR-858/)
Report a problem