REVIVE VI Act

HR 858, the REVIVE VI Act, exempts certain income earned by Virgin Islands businesses from global tax rules that typically apply to foreign-owned companies. Specifically, it creates a new category of "qualified Virgin Islands services income" for Virgin Islands corporations performing services within the territory, excluding this income from the global intangible low-taxed income (GILTI) tax calculation. This directly benefits Virgin Islands-based service providers and their "specified United States shareholders" (including individuals, trusts, estates, or closely held C corporations that owned the business before 2023). The change reduces tax liability for qualifying businesses operating in the U.S. Virgin Islands, aiming to boost local economic activity.