H.R. 858 – REVIVE VI Act

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Updated November 24, 2025 at 3:07 AM UTC

The REVIVE VI Act changes the tax code so that income earned from services performed in the U.S. Virgin Islands by Virgin Islands‑incorporated businesses is not counted toward a U.S. shareholder’s global intangible low‑taxed income (GILTI). This provides tax relief to U.S. individuals, trusts, estates, and certain small C corporations that own shares in such Virgin Islands companies, encouraging investment and economic activity in the islands.

Key Provisions

Adds a new sub‑clause to the GILTI definition that lets certain "qualified Virgin Islands services income" be ignored when calculating a shareholder’s global intangible low‑taxed income.
Defines "qualified Virgin Islands services income" as compensation for labor or personal services performed in the Virgin Islands by a corporation organized there, that is attributable to services done within the islands and is effectively connected with a trade or business in the islands.
Defines a "specified United States shareholder" as an individual, trust, estate, or a closely‑held C corporation that bought its interest in the foreign corporation before Dec. 31, 2023.
Requires the Treasury Secretary to issue regulations to implement the new rule and prevent abuse.
Makes the changes apply to foreign corporations’ taxable years that begin after the law is enacted, and to the U.S. shareholders’ years that include those foreign years.

Legislative Activity

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1 earlier action

HouseIntro Referral Latest Action

Referred to the House Committee on Ways and Means.

Ways and Means Committee

January 31, 2025

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HouseIntro Referral

Introduced in House

January 31, 2025

HouseIntro Referral

Referred to the House Committee on Ways and Means.

Ways and Means Committee

January 31, 2025

Bill Text

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Introduced in HouseIssued January 31, 2025

I

119th CONGRESS

1st Session

H. R. 858

IN THE HOUSE OF REPRESENTATIVES

January 31, 2025

Mr. Estes (for himself, Ms. Plaskett, Mr. Hern of Oklahoma, Ms. Sewell, Mr. Feenstra, and Mr. Schneider) introduced the following bill; which was referred to the Committee on Ways and Means

A BILL

To amend the Internal Revenue Code of 1986 to determine global intangible low-taxed income without regard to certain income derived from services performed in the Virgin Islands.

1.

Short title

This Act may be cited as the Restore Economic Vitality and Investment in the Virgin Islands Act or the REVIVE VI Act.

2.

Global intangible low-taxed income determined without regard to certain income derived from services performed in the Virgin Islands

(a)

In general

Section 951A(c)(2)(A)(i) of the Internal Revenue Code of 1986 is amended by striking and at the end of subclause (IV), by striking the period at the end of subclause (V) and inserting , and, and by adding at the end the following new subclause:

(VI)

in the case of any specified United States shareholder, any qualified Virgin Islands services income.

.

(b)

Definitions and special rules

Section 951A(c)(2) of such Code is amended by adding at the end the following new subparagraph:

(C)

Provisions related to qualified Virgin Islands services income

For purposes of subparagraph (A)(i)(VI)—

(i)

Qualified Virgin Islands services income

The term qualified Virgin Islands services income means any gross income which satisfies all of the following requirements:

(I)

Such gross income is compensation for labor or personal services (within the meaning of section 862(a)(3)) performed in the Virgin Islands by a corporation formed under the laws of the Virgin Islands.

(II)

Such gross income is attributable to services performed from within the Virgin Islands by individuals for the benefit of such corporation.

(III)

Such gross income is effectively connected with the conduct of a trade or business within the Virgin Islands.

(ii)

Specified United States shareholder

The term specified United States shareholder means any United States shareholder which is—

(I)

an individual, trust, or estate, or

(II)

a closely held C corporation (as defined in section 469(j)(1)) if such corporation acquired its direct or indirect equity interest in the foreign corporation which derived the qualified Virgin Islands services income before December 31, 2023.

(iii)

Regulations

The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out this subparagraph and subparagraph (A)(i)(VI), including regulations or other guidance to prevent the abuse of such subparagraphs.

.

(c)

Effective date

The amendments made by this section shall apply to taxable years of foreign corporations beginning after the date of the enactment of this Act, and to taxable years of United States shareholders with or within which such taxable years of foreign corporations end.