119th Congress Taxation
H.R. 364: Territorial Tax Equity and Economic Growth Act of 2025
Introduced
- Introduced (completed)
- Passed House (not reached)
- Passed Senate (not reached)
- To the President (not reached)
- Became law (not reached)
Summary
This bill lowers the residency requirements and modifies the income sourcing rules related to taxation of income from U.S. territories.
Currently, bona fide residents of a U.S. territory may exclude income sourced to the territory in calculating U.S. federal income tax. A bona fide resident of a territory is a person that, in part, is present in the territory for at least 183 days in a tax year. Income is sourced to a U.S. territory if it is not U.S.-sourced income or effectively connected with a U.S. trade or business.
This bill
Read the full summary
- reduces the presence requirement to 122 days,
- specifies that income is U.S.-sourced income or effectively connected to a U.S. trade or business only if attributable to an office or fixed place of business in the United States, and
- specifies that income from U.S.-based activities that are preparatory or auxiliary may not be considered U.S.-sourced income.
Currently, income from certain personal property sales from a fixed place of business in a U.S. territory by a U.S. resident may be U.S.-sourced income unless an income tax of at least 10% is paid to the U.S. territory. The Internal Revenue Service (IRS) may limit the 10% tax payment requirement related to income from personal property sales in Guam, American Samoa, the Northern Mariana Islands, and Puerto Rico. This bill expands the IRS’s authority to include limiting the tax requirement for personal property sales in the Virgin Islands.
Written by the Congressional Research Service, Library of Congress.
Roll calls
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Amendments
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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.