REVIVE VI Act

The REVIVE VI Act would amend the Internal Revenue Code to address what supporters describe as an unintended consequence of the 2017 Tax Cuts and Jobs Act. The bill would exclude income from personal services performed in the U.S. Virgin Islands from the Global Intangible Low Tax Income (GILTI) taxation framework, but only for individual shareholders, estates, and trusts, as well as closely held corporations that acquired their shares before 2024.

Under current law, U.S. mainland residents who own shares in USVI businesses are subject to GILTI taxes on income derived from services performed in the territory, while foreign shareholders in the same corporations are not. Proponents argue this creates an unequal tax burden that discourages American investment in the territory and undermines Congress's previous efforts to support economic development in the USVI. The bill is designed to be narrowly tailored to fix this specific issue while preventing potential abuse by large multinational corporations seeking to avoid taxation.

The bill is currently under consideration by the House Ways and Means Committee. It has bipartisan support, with cosponsors from both parties, though it faces an uncertain path forward in the legislative process.