Bill 119 HR 858, also known as the "Global Intangible Low-Taxed Income (GILTI) Act," aims to make changes to the Internal Revenue Code of 1986. Specifically, this bill seeks to alter how global intangible low-taxed income is calculated, by excluding certain income derived from services performed in the Virgin Islands.
The GILTI provision was originally introduced as part of the Tax Cuts and Jobs Act of 2017, in an effort to prevent multinational corporations from shifting profits to low-tax jurisdictions. However, there have been concerns raised about the impact of this provision on businesses operating in the Virgin Islands, as it could potentially result in double taxation for income earned in that territory.
By amending the calculation of GILTI to exclude income derived from services performed in the Virgin Islands, this bill aims to address these concerns and ensure that businesses operating in the territory are not unfairly penalized. This change would help to provide clarity and consistency in the tax treatment of income earned in the Virgin Islands, while still maintaining the overall integrity of the GILTI provision.
Overall, Bill 119 HR 858 seeks to make targeted adjustments to the tax code in order to promote fairness and efficiency in the taxation of global intangible low-taxed income.