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effectively 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 ... goods in the U.S. 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