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The REVIVE VI Act amends the Internal Revenue Code to exclude certain income derived from services performed in the U.S. Virgin Islands from the calculation of global intangible low-taxed income (GILTI) for specified U.S. shareholders. The exclusion applies to compensation for labor or personal services performed in the Virgin Islands by Virgin Islands-formed corporations, provided the income is effectively connected with a trade or business in the territory. The bill targets individuals, trusts, estates, and closely held C corporations that acquired their interests in the foreign corporation before December 31, 2023.
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