26 U.S.C. § 934: Limitation on reduction in income tax liability incurred to the Virgin Islands

Tax liability incurred to the Virgin Islands pursuant to this subtitle, as made applicable in the Virgin Islands by the Act entitled “An Act making appropriations for the naval service for the fiscal year ending June 30, 1922 , and for other purposes”, approved July 12, 1921 ( 48 U.S.C. 1397 ), or pursuant to section 28(a) of the Revised Organic Act of the Virgin Islands, approved July 22, 1954 ( 48 U.S.C. 1642 ), shall not be reduced or remitted in any way, directly or indirectly, whether by grant, subsidy, or other similar payment, by any law enacted in the Virgin Islands, except to the extent provided in subsection (b). Except as provided in paragraph (2), subsection (a) shall not apply with respect to so much of the tax liability referred to in subsection (a) as is attributable to income derived from sources within the Virgin Islands or income effectively connected with the conduct of a trade or business within the Virgin Islands. Paragraph (1) shall not apply to any liability payable to the Virgin Islands under section 932(b). In the case of a qualified foreign corporation, subsection (a) shall not apply with respect to so much of the tax liability referred to in subsection (a) as is attributable to income which is derived from sources outside the United States and which is not effectively connected with the conduct of a trade or business within the United States. the total voting power of the stock of such corporation, and the total value of the stock of such corporation, is owned or treated as owned (within the meaning of section 958) by 1 or more United States persons. The determination as to whether income is derived from sources within the United States or is effectively connected with the conduct of a trade or business within the United States shall be made under regulations prescribed by the Secretary. Except as provided in paragraph (2), the amendments made by this section [enacting section 934A and amending this section] shall apply to amounts received after the date of the enactment of this Act [ Jan. 12, 1983 ] in taxable years ending after such date. The amendment made by subsection (b) [enacting section 1444 of this title ] shall apply to payments made after the date of the enactment of this Act.”