To amend the Internal Revenue Code of 1986 to provide that certain bona fide residents of the Virgin Islands who are shareholders of corporations organized under the laws of the Virgin Islands are not treated as United States persons for purposes of determining certain inclusions in gross income with respect to such corporations.

This bill sets forth a tax rule with respect to certain bona fide residents of the U.S. Virgin Islands who are shareholders of corporations organized under the laws of the Virgin Islands. It provides that such residents shall not be treated as U.S. persons for purposes of determining inclusions in gross income with respect to such corporations.