REVIVE VI Act

HR 10503, the REVIVE VI Act, exempts certain income earned by Virgin Islands corporations from U.S. tax on foreign income (GILTI). It directly affects Virgin Islands corporations providing services within the territory and specific U.S. shareholders (individuals, trusts, estates, or certain pre-2023-owned C corporations). The bill creates a new tax exemption for "qualified Virgin Islands services income," defined as compensation for labor performed in the Virgin Islands by a local corporation, attributable to services from within the territory, and connected to a Virgin Islands business. This change modifies the Internal Revenue Code to exclude this specific income from global intangible low-taxed income calculations for eligible entities.