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119-hr-365119th CongressWALLET

Territorial Tax Parity Act of 2025

Sponsored By: Representative Plaskett, Stacey E. [D-VI-At Large]

Introduced

Summary

Territorial tax parity for U.S. possessions is the bill's main aim. It would change how income tied to possessions is sourced for U.S. tax rules and add a new cross‑reference affecting sales of personal property.

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  • Businesses operating in U.S. possessions would face a narrower test for when income is treated as attributable to a U.S. office or fixed place, using the attribution rules in section 864(c)(5).
  • Sellers of personal property that involve U.S. possessions would see the sale-of-personal-property sourcing rules expanded by adding a cross-reference to section 932 after section 931 in section 865(j)(3).
  • Taxpayers and tax advisers would need to apply these new sourcing rules for taxable years beginning after December 31, 2024.

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Bill Overview

Analyzed Economic Effects

1 provisions identified: 0 benefits, 0 costs, 1 mixed.

New territory income tax rules

This bill would change how income tied to U.S. territories is sourced for tax. Income would be treated as U.S. source to the extent it is attributable to a U.S. office or fixed place of business, using section 864(c)(5). It would also apply section 932, along with section 931, to the sale‑of‑personal‑property sourcing rule. These changes would start for tax years beginning after December 31, 2024. If passed, some businesses and investors could owe more or less U.S. tax depending on their facts.

Sponsors & CoSponsors

Sponsor

Plaskett, Stacey E. [D-VI-At Large]

VI • D

Cosponsors

There are no cosponsors for this bill.

Roll Call Votes

No roll call votes available for this bill.

View on Congress.gov
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