EFTA00301255Set 9
2016-12-3148p19,426w
connected with the conduct of a V.I. trade or business," regardless of source ("V.I. ECI"). This
provision is a potentially powerful incentive for attracting investment to the Virgin Islands ... Section 937, which provides that no U.S. source income can qualify as V.I. ECI (the "U.S.
income limitation") unless specifically permitted under rules promulgated by the Treasury.
To date, Treasury ... market (which would constitute U.S. source income) to qualify as V.I. ECI,
based on the Department's constrained interpretation of an express legislative statement in the
Jobs Act that Congress
https://www.justice.gov/epstein/files/DataSet%209/EFTA00301255.pdf