119th Congress Taxation
H.R. 363: Territorial Economic Recovery Act
Introduced
- Introduced (completed)
- Passed House (not reached)
- Passed Senate (not reached)
- To the President (not reached)
- Became law (not reached)
Summary
This bill excludes the income of certain controlled foreign corporations in U.S. territories from the calculation of global intangible low-taxed income (GILTI) for federal tax purposes.
Under current law, a U.S. shareholder of a controlled foreign corporation is required to include in gross income the GILTI of the shareholder. The calculation of GILTI is based, in part, on the controlled foreign corporation’s tested income (the controlled foreign corporation’s gross income less certain exclusions).
Under the bill, the income from a qualified possession corporation that is effectively connected with an active trade or business within a U.S. territory (Puerto Rico, U.S. Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands) is excluded from gross income for purposes of calculating a controlled foreign corporation’s tested income.
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The bill defines a qualified possession corporation as any controlled foreign corporation if, for a three-year period ending in the prior tax year (or for the existence of the controlled foreign corporation if less than three years) (1) 80% or more of the controlled foreign corporation’s gross income was derived from a U.S. territory, and (2) 75% or more of the controlled foreign corporation’s gross income was effectively connected to the active conduct of a trade or business within a U.S. territory.
Written by the Congressional Research Service, Library of Congress.
Roll calls
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Amendments
No amendments were offered to this bill.
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Other bills by Stacey Plaskett
- H.R. 8121: To designate the Christiansted Bandstand at the Christiansted National Historic Site, St. Croix, Virgin Islands, as the "Peter G. Thurland, Sr., Bandstand".
- H.R. 1737: To direct the Secretary of Commerce to submit to Congress a report containing an assessment of the value, cost, and feasibility of a trans-Atlantic submarine fiber optic cable connecting the contiguous United States, the United States Virgin Islands, Ghana, and Nigeria.
- H.R. 5034: Lieutenant General Samuel E. Ebbesen Post Office (Christiansted, St. Croix, VI)
- H.R. 3385: DiasporaLink Act
History
- Introduced in the House by Stacey Plaskett.
Show the full action history (2 actions)
- Introduced in House
- Referred to the House Committee on Ways and Means.