n its alternative proposal a new statutory framework, not included in either the Senate- or House-passed bills, which severely limits the amount of USVI ECI that can qualify for EDC benefits. The Treasury substitute generally provided that rules "similar to" the .rules for determining whether income is i

ross income of $155,000, comprising income from sources within the USVI or effectively connected to the conduct of a trade or business in the USVI (USVI ECI) of $75,000, income from sources within the United States of $50,000, and income from other sources (not USVI ECI) of $30,000. After taking into ac