§ 934. Limitation on reduction in income tax liability incurred to the Virgin Islands
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(a)General rule Tax liability incurred to the Virgin Islands pursuant to this subtitle, as made applicable in the Virgin Islands by the Act entitled “An Act making appropriations for the naval service for the fiscal year ending June 30, 1922, and for other purposes”, approved July 12, 1921 (48 U.S.C. 1397), or pursuant to section 28(a) of the Revised Organic Act of the Virgin Islands, approved July 22, 1954 (48 U.S.C. 1642), shall not be reduced or remitted in any way, directly or indirectly, whether by grant, subsidy, or other similar payment, by any law enacted in the Virgin Islands, except to the extent provided in subsection (b).
(b)Reductions permitted with respect to certain income
(1)In general Except as provided in paragraph (2), subsection
(a)shall not apply with respect to so much of the tax liability referred to in subsection
(a)as is attributable to income derived from sources within the Virgin Islands or income effectively connected with the conduct of a trade or business within the Virgin Islands.
(2)Exception for liability paid by citizens or residents of the United States Paragraph
(1)shall not apply to any liability payable to the Virgin Islands under section 932(b).
(3)Special rule for non-United States income of certain foreign corporations
(A)In general In the case of a qualified foreign corporation, subsection
(a)shall not apply with respect to so much of the tax liability referred to in subsection
(a)as is attributable to income which is derived from sources outside the United States and which is not effectively connected with the conduct of a trade or business within the United States.
(B)Qualified foreign corporation For purposes of subparagraph (A), the term “qualified foreign corporation” means any foreign corporation if less than 10 percent of—
(i)the total voting power of the stock of such corporation, and
(ii)the total value of the stock of such corporation, is owned or treated as owned (within the meaning of section 958) by 1 or more United States persons.
(4)Determination of income source, etc. The determination as to whether income is derived from sources within the United States or is effectively connected with the conduct of a trade or business within the United States shall be made under regulations prescribed by the Secretary.
(Added Pub. L. 86–779, § 4(a)(1), Sept. 14, 1960, 74 Stat. 998; amended Pub. L. 94–455, title XIX, §§ 1901(a)(118), 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1784, 1834; Pub. L. 97–248, title II, § 213(b), Sept. 3, 1982, 96 Stat. 463; Pub. L. 97–455, § 1(c), Jan. 12, 1983, 96 Stat. 2498; Pub. L. 98–369, div. A, title VIII, § 801(d)(7), July 18, 1984, 98 Stat. 996; Pub. L. 99–514, title XII, § 1275(a)(2)(A), (c)(1), (2), title XVIII, § 1876(f)(2), Oct. 22, 1986, 100 Stat. 2598, 2900; Pub. L. 108–357, title VIII, § 908(c)(3), Oct. 22, 2004, 118 Stat. 1656.)
Connections7 cite this · traces to 10
Cited by 7 sections · top 6
statutes-at-large
- Public Law 98–369To provide for tax reform, and for deficit reduction
- Public Law 97–455To amend the Internal Revenue Code of 1954 to reduce the rate of certain taxes paid to the Virgin Islands on Virgin Islands source income, to amend the Social Security Act to provide for a temporary period that payment of disability benefits may continue through the hearing stage of the appeals proc
- Public Law 97–248To provide for tax equity and fiscal responsibility, and for other purposes
- Public Law 94–455To reform the tax laws of the United States
register
Traces to 10 documents
U.S. Code
- Income tax laws of United States in force; payment of proceeds; levy of surtax on all taxpayers§ 1397
- Use of certain proceeds for expenditure; income tax obligations of inhabitants§ 1642
- Residence and source rules involving possessions§ 937
- Income from sources within Guam, American Samoa, or the Northern Mariana Islands§ 931
- Energy credit§ 48
- Dividends received from certain foreign corporations§ 245
- Withholding on Virgin Islands source income§ 1444
- Rules applying to deductions for dividends received§ 246
- Definitions and special rules§ 2
- Qualified pension, profit-sharing, and stock bonus plans§ 401
39 references not yet in our index
- Pub. L. 86–779, § 4(a)(1)
- 74 Stat. 998
- Pub. L. 94–455, title XIX
- 90 Stat. 1784
- Pub. L. 97–248, title II, § 213(b)
- 96 Stat. 463
- Pub. L. 97–455, § 1(c)
- 96 Stat. 2498
- Pub. L. 98–369, div. A, title VIII, § 801(d)(7)
- 98 Stat. 996
- Pub. L. 99–514, title XII, § 1275(a)(2)(A)
- 100 Stat. 2598
- Pub. L. 108–357, title VIII, § 908(c)(3)
- 118 Stat. 1656
- Pub. L. 108–357
- Pub. L. 99–514, § 1275(c)(2)(A)
- Pub. L. 99–514, § 1275(c)(1)
- Pub. L. 99–514, § 1275(a)(2)(A)
- Pub. L. 99–514, § 1876(f)(2)
- Pub. L. 98–369
- Pub. L. 97–455
- Pub. L. 97–248, § 213(b)(1)
- Pub. L. 97–248, § 213(b)(2)
- Pub. L. 94–455, § 1901(a)(118)
- Pub. L. 94–455, § 1906(b)(13)(A)
- section 908(d)(1) of Pub. L. 108–357
- Pub. L. 99–514
- section 1277 of Pub. L. 99–514
- section 1876(f)(2) of Pub. L. 99–514
- Pub. L. 98–369, div. A
- section 1881 of Pub. L. 99–514
- section 805(a)(1) of Pub. L. 98–369
- Pub. L. 97–455, § 1(e)
- Pub. L. 97–248
- section 1901(a)(118) of Pub. L. 94–455
- section 1901(d) of Pub. L. 94–455
- Pub. L. 86–779, § 4(e)(1)
- 74 Stat. 1000
- section 1140 of Pub. L. 99–514
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cites case law
§ 934
Limitation on reduction in income tax liability incurred to the Virgin Islands
Stat.×5
Fed. Reg.×1
U.S.C.×1
Pub. L.Pub. L. 86–779, § 4(a)(1)
Stat.74 Stat. 998
Pub. L.Pub. L. 94–455, title XIX
Cites 49 · showing 12Cited by 7 across 3 sources