Abstract

The big news regarding changes in United States laws which affect US Virgin Islands trustees, trusts and trust settlors and beneficiaries is that some of the hoped for and worked for liberalizations in the law as applied to the US Virgin Islands have partially come about. The US Virgin Islands has authority to grant certain income tax reductions, but to qualify one must be a bona fide resident of the US Virgin Islands. In 2004, the US Congress added the requirement that to qualify as a bona fide resident of the US Virgin Islands for any particular year a taxpayer must spend at least 183 days during the year physically present in the territory. In 2006, the US Internal Revenue Service issued Regulations allowing alternatives to actually being present in the US Virgin Islands that would not disqualify an otherwise qualified resident: first, a taxpayer who is in the United...

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