Territorial Tax Parity and Fairness Act

Section 957(c) of the Internal Revenue Code of 1986 is amended by striking and at the end of paragraph (1), by redesignating paragraph (2) as paragraph (3), and by inserting after paragraph (1) the following new paragraph:

(2) with respect to a corporation organized under the laws of the Virgin Islands, such term does not include an individual who is a bona fide resident of the Virgin Islands, if a dividend received by such individual during the taxable year from such corporation would, for purposes of section 934(b)(1), be treated as income derived from sources within the Virgin Islands, and

Section 957(c) of such Code is amended by striking paragraph (2) in the last sentence and inserting paragraph (3).

The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2024, and taxable years of individuals within which or with which such taxable years of foreign corporations end.