REVIVE VI Act

This bill proposes to amend the Internal Revenue Code of 1986 by modifying the calculation of global intangible low-taxed income (GILTI) . Its primary aim is to exclude certain income generated from services performed in the Virgin Islands from this tax base, potentially reducing the tax burden on specific U.S. shareholders. The legislation introduces a new category called "qualified Virgin Islands services income," defined as gross income from labor or personal services performed in the Virgin Islands by a Virgin Islands corporation. This income must be attributable to services rendered within the Virgin Islands by individuals for the corporation and effectively connected with a trade or business conducted there. This exclusion from GILTI applies to "specified United States shareholders," including individuals, trusts, estates, and certain closely held C corporations that acquired their interest before December 31, 2023. The Secretary of the Treasury is authorized to issue regulations to prevent abuse, with the amendments taking effect for foreign corporations' taxable years beginning after the bill's enactment.