Section 1 Short title
This Act may be cited as the “Territorial Tax Parity and Fairness Act”.
Territorial Tax Parity and Fairness Act
A BILL
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.
Sec. 2 Certain bona fide residents of Virgin Islands
In general— Section 957(c) of the Internal Revenue Code of 1986 is amended by striking “and” at the end of paragraph (1), by redesignating paragraph (2) as paragraph (3), and by inserting after paragraph (1) the following new paragraph:
“(2) with respect to a corporation organized under the laws of the Virgin Islands, such term does not include an individual who is a bona fide resident of the Virgin Islands, if a dividend received by such individual during the taxable year from such corporation would, for purposes of section 934(b)(1), be treated as income derived from sources within the Virgin Islands, and”
Conforming amendment— Section 957(c) of such Code is amended by striking “paragraph (2)” in the last sentence and inserting “paragraph (3)”.
Effective date— The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2024, and taxable years of individuals within which or with which such taxable years of foreign corporations end.