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) 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) 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 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.

(a) In general Section 951A(c)(2)(A)(i) is amended by striking and at the end of subclause (IV), by striking, over 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, over. (b) Definitions and special rules Section 951A(c)(2) 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 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.