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H.R. 363

U.S. House•In House Committee

Summary

H.R. 363, the Territorial Economic Recovery Act, was introduced in the House on Jan 13, 2025 by Rep. Stacey Plaskett (D). It was referred to Ways And Means, and last saw action on Jan 13, 2025: Referred to the House Committee on Ways and Means.

Record

Text

H.R. 363 has no co-sponsors and has not gone to a roll call.

hb363/introduced-in-house.txt
119 HR 363 IH: Territorial Economic Recovery Act
 U.S. House of Representatives
 2025-01-13
 text/xml
 EN
 Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain.
 I  119th CONGRESS  1st Session  H. R. 363  IN THE HOUSE OF REPRESENTATIVES   January 13, 2025   Ms. Plaskett  introduced the following bill; which was referred to the  Committee on Ways and Means    A BILL
To amend the Internal Revenue Code of 1986 to exclude certain amounts from the tested income of controlled foreign corporations, and for other purposes.
1.
Short title
This Act may be cited as the   Territorial Economic Recovery Act  .
2.
Income of certain qualified possession corporations excluded from tested income
(a)
In general
 Section 951A  of the Internal Revenue Code of 1986 is amended—
(1)
in subsection (c)(2)(A)(i), by striking  and  at the end of subclause (IV), by striking  over  at the end of subclause (V) and inserting  and , and by adding at the end the following new subclause:
(VI)
any income of a qualified possession corporation that is effectively connected with the active conduct of a trade or business within a possession of the United States, over
  ; and
(2)
by adding at the end the following new subsections:
(g)
Possession of the united states
For purposes of this section, the term  possession of the United States  means Puerto Rico, the Virgin Islands, and any specified possession described in section 931(c).
(h)
Qualified possession corporation
For purposes of this section, the term  qualified possession corporation  means any controlled foreign corporation for any taxable year, if, for the 3-year period (or the period during which the controlled foreign corporation has been in existence, if shorter) ending in the taxable year preceding the taxable year in which the determination is made—
(1)
80 percent or more of the gross income of such corporation was derived from sources within a possession of the United States, and
(2)
75 percent or more of the gross income of such corporation was effectively connected with the active conduct of a trade or business within a possession of the United States.
 .
(b)
Effective date
The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2023, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.

Tracker

The tracker indicates the progress of this legislation as it moves through the legislative process.

  1. Introduced2025-01-13
  2. Passed House
  3. Passed Senate
  4. Conference
  5. To President
  6. Became Law

CRS Summary

The summaries are the Congressional Research Service’s, one per stage. Read them in full.

Introduced in House Jan 13, 2025

hb363/introduced-in-house.md

Shown Here:
Introduced in House (01/13/2025)

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.

Sponsors

Rep. Stacey Plaskett (D) sponsors H.R. 363 alone.

Stacey Plaskett

Rep. · D–VI · Sponsor

Committees

H.R. 363 went before 1 committee: Ways and Means.

Ways and Means
Ways and Means
Referred To · Jan 13, 2025 · 1,160 Bills

Actions

H.R. 363 has taken 2 actions since Jan 13, 2025.

ChamberAction
Jan 13, 2025
House
Introduced in House
Jan 13, 2025
House
Referred to the House Committee on Ways and Means.Ways and Means Committee

Votes

H.R. 363 has not gone to a roll call.

Titles

H.R. 363 goes by 3 titles, 1 of them short titles.

  • Territorial Economic Recovery Act — Display Title
  • Territorial Economic Recovery Act — Short Title(s) as Introduced
  • To amend the Internal Revenue Code of 1986 to exclude certain amounts from the tested income of controlled foreign corporations, and for other purposes. — Official Title as Introduced

Lobbying

1 client hired 1 firm and 5 registered lobbyists who named H.R. 363 in 2 quarterly filings, 2026. Reported under the Lobbying Disclosure Act; a filing’s income covers everything its registrant worked that quarter, so the amounts below are the filings’, not this bill’s.

Filed under Health Issues, Medicare/Medicaid, Pharmacy, Taxation/Internal Revenue Code, Trade (domestic/foreign).

Clients

Who paid to be heard, by how many filings named the bill.

ClientBusinessStateFirmsFilingsReported
CENCORA, INC.—District of Columbia12—

Firms

Registrants who filed on the bill, by filings.

RegistrantClientsFilingsReported
CENCORA, INC.12—

Lobbyists

Named on the filings that cite the bill.

LobbyistFirmsClientsFilings
COREY MCGEE112
DARRELL ROGERS112
FREDERICK ESSIS112
SHELLY MUI-LIPNIK112
VIVIENNE MITCHELL112

Filings

The documents themselves, on the Senate’s Lobbying Disclosure site, largest reported first.

ClientRegistrantPeriodReportedDocument
CENCORA, INC.CENCORA, INC.2026 first_quarter$1.2M1st Quarter - Report
CENCORA, INC.CENCORA, INC.2026 second_quarter$510K2nd Quarter - Report

Classification

The Congressional Research Service files H.R. 363 under Taxation, one of its 31 policy areas, and gives it 8 legislative subjects.

CRS Subjects

CRS assigns every bill one policy area from its 31; H.R. 363’s is Taxation.

hr363/policy-areas.txt
TaxationAgriculture and FoodAnimalsArmed Forces and National SecurityArts, Culture, ReligionCivil Rights and Liberties, Minority IssuesCommerceCongressCrime and Law EnforcementEconomics and Public FinanceEducationEmergency ManagementEnergyEnvironmental ProtectionFamiliesFinance and Financial SectorForeign Trade and International FinanceGovernment Operations and PoliticsHealthHousing and Community DevelopmentImmigrationInternational AffairsLabor and EmploymentLawNative AmericansPublic Lands and Natural ResourcesScience, Technology, CommunicationsSocial WelfareSports and RecreationTransportation and Public WorksWater Resources Development

Legislative Subjects

H.R. 363 carries 8 of CRS’s legislative subjects, from American Samoa to Virgin Islands.

hr363/subjects.txt
American SamoaGuamIncome tax exclusionNorthern Mariana IslandsPuerto RicoTaxation of foreign incomeU.S. territories and protectoratesVirgin Islands

Constitutional authority

The clause the sponsor cites as Congress’s power to enact H.R. 363, as entered in the Congressional Record.

[Congressional Record Volume 171, Number 6 (Monday, January 13, 2025)][House]From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]By Ms. PLASKETT:H.R. 363.Congress has the power to enact this legislation pursuantto the following:Article I, Section 8 of the Constitution.[Page H112]

Source: congress.gov · legiscan.com