H.R. 363: Territorial Economic Recovery Act

119th Congress · introduced 2025-01-13 · Taxation · Latest: Referred to the House Committee on Ways and Means.

federal

Official title

Territorial Economic Recovery Act

Plain summary

Territorial Economic Recovery Act This bill excludes the income of certain controlled foreign corporations in U.S. territories from the calculation of global intangible low-taxed income (GILTI) for federal tax purposes. Under current law, a U.S. shareholder of a controlled foreign corporation is required to include in gross income the GILTI of the shareholder. The calculation of GILTI is based, in part, on the controlled foreign corporation’s tested income (the controlled foreign corporation’s gross income less certain exclusions). Under the bill, the income from a qualified possession corporation that is effectively connected with an active trade or business within a U.S. territory (Puerto Rico, U.S. Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands) is excluded from gross income for purposes of calculating a controlled foreign corporation’s tested income. The bill defines a qualified possession corporation as any controlled foreign corporation if, for a three-year period ending in the prior tax year (or for the existence of the controlled foreign corporation if less than three years) (1) 80% or more of the controlled foreign corporation’s gross income was derived from a U.S. territory, and (2) 75% or more of the controlled foreign corporation’s gross income was effectively connected to the active conduct of a trade or business within a U.S. territory.

Congressional Research Service summary (Introduced in House), quoted unchanged (nonpartisan). Read the source.

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Official text

Territorial Economic Recovery Act

Source: Congressional Research Service summary (Introduced in House)

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Officials and money

Sponsor: Del. Plaskett, Stacey E. [D-VI] · 0 cosponsors

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Words on this page, explained (1)

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Sources

Congressional Research Service summary (Introduced in House)
Congress.gov
Data: GovInfo BILLSTATUS bulk data (Library of Congress), BILLSTATUS-119hr363.xml <https://www.govinfo.gov/bulkdata/BILLSTATUS/119/hr>

Record fed-us-cong119-hr363 · catalog fed-us-congress-bills-cong119 · updated 2026-11-03 by psicol fed-bills