# 119-hr-363: Territorial Economic Recovery Act

119-hr-363, Territorial Economic Recovery Act, is a 119th Congress bill sponsored by Del. Plaskett, Stacey E. [D-VI-At Large] (D-VI); status introduced; PRIA reads it as touching household money (as of 2026-05-01).

- Canonical: https://policyrisk.com/legislation/119-hr-363
- As of: 2026-05-01
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-hr-363
- Congress: 119
- Title: Territorial Economic Recovery Act
- Status: introduced
- Introduced: 2025-01-13
- Sponsor: Del. Plaskett, Stacey E. [D-VI-At Large] (D-VI)
- Cosponsors: 0
- Policy area: Taxation
- Touches household money: yes
- Last recorded action: 2026-05-01

## Summary

**This bill would create a new rule that **excludes active, possession-based income from GILTI for qualifying possession corporations**. It targets companies operating in Puerto Rico, the U.S. Virgin Islands, and other specified U.S. possessions and narrows which foreign earnings count toward GILTI.** - Possession-based corporations that qualify as a "qualified possession corporation" would have income that is effectively connected with active trade or business in a possession excluded from a controlled foreign corporation's GILTI tested income. Qualification uses a 3-year lookback with two thresholds: at least 80% of gross income from possession sources and at least 75% of gross income effectively connected to active business in the possession. - U.S. shareholders of those controlled foreign corporations would generally face lower GILTI inclusion for the years the foreign entity meets the tests, reducing the portion of foreign earnings counted under GILTI for U.S. tax purposes. - The rule would apply to foreign corporations' taxable years beginning after December 31, 2023, and to U.S. shareholder years that include or align with those foreign tax years. The change works within existing concepts of source and effectively connected income and does not create new credits or appropriations.

## Provisions PRIA read

- Lower U.S. tax on possession business income: benefit, low. This bill would change how GILTI is figured for some companies in U.S. possessions. U.S. shareholders of a qualified possession corporation would not count its income tied to active business in the possession when figuring GILTI. A company would qualify if, over the last 3 years (or since it began)…

## Related bills

- 119-hr-6900: American Affordability Act of 2025
- 119-hr-3077: Agriculture Resilience Act of 2025
- 119-hr-7973: Momnibus Act
- 119-hr-4312: SCORE Act
- 119-hr-5862: American Energy Independence and Affordability Act
- 119-hr-5361: George Floyd Justice in Policing Act of 2025

## Sources
- [119-hr-363 on Congress.gov](https://www.congress.gov/bill/119th-congress/house-bill/363)

## Related
- [119-hr-6900: American Affordability Act of 2025](https://policyrisk.com/legislation/119-hr-6900)
- [119-hr-3077: Agriculture Resilience Act of 2025](https://policyrisk.com/legislation/119-hr-3077)
- [119-hr-7973: Momnibus Act](https://policyrisk.com/legislation/119-hr-7973)
- [119-hr-4312: SCORE Act](https://policyrisk.com/legislation/119-hr-4312)
- [119-hr-5862: American Energy Independence and Affordability Act](https://policyrisk.com/legislation/119-hr-5862)
- [119-hr-5361: George Floyd Justice in Policing Act of 2025](https://policyrisk.com/legislation/119-hr-5361)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-hr-363 (as of 2026-05-01).