119th Congress · introduced in the House · Jan 13, 2025
Territorial Economic Recovery Act
Official title from Congress.gov
Latest action (Jan 13, 2025): Referred to the House Committee on Ways and Means.
View on Congress.govPolicy area: Taxation
Congressional Research Service summary, version: Introduced in House (Jan 13, 2025)
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.
No cosponsors.
Includes amendment, cloture, and procedural votes. Each is labeled with its exact question; only a passage question is a vote to pass the bill.
No recorded roll calls on this bill in coverage.
Referred to the House Committee on Ways and Means.
Introduced in House
Introduced in House
Actions from Congress.gov, newest first.
American Samoa · Guam · Income tax exclusion · Northern Mariana Islands · Puerto Rico · Taxation of foreign income · U.S. territories and protectorates · Virgin Islands
LD-2 reports whose issue descriptions explicitly cite this bill (bill type and number validated against Congress.gov records). A citation does not establish the client's position or any contact with a member.
Loading lobbying reportsCoverage: reports for 2025 onward, posted Jan 1, 2025 through Oct 23, 2026.
2 citations.
CENCORA, INC. · lobbying firm or registrant: CENCORA, INC.
2026 Q2 report (Apr 1, 2026 – Jun 30, 2026) · posted Jul 20, 2026 · issue area: Taxation/Internal Revenue Code
$510,000
Spent on own lobbying
Global Intangible Low-taxed Income (GILTI) Territorial Economic Recovery Act (H.R. 363) The Medical Manufacturing, Economic Development, and Sustainability (MMEDS) Act (H.R. 3042) Restore Economic Vitality and Investment in the Virgin Islands Act…
Congress inferred from the report year; bill number and the title cited with it match Congress.gov records, and the bill predates the report. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
CENCORA, INC. · lobbying firm or registrant: CENCORA, INC.
2026 Q1 report (Jan 1, 2026 – Mar 31, 2026) · posted Apr 21, 2026 · issue area: Taxation/Internal Revenue Code
$1,150,000
Spent on own lobbying
Global Intangible Low-taxed Income (GILTI) Territorial Economic Recovery Act (H.R. 363) The Medical Manufacturing, Economic Development, and Sustainability (MMEDS) Act (H.R. 3042) Restore Economic Vitality and Investment in the Virgin Islands Act…
Congress inferred from the report year; bill number and the title cited with it match Congress.gov records, and the bill predates the report. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing