gn taxpayers. Second, it would eliminate the economic distortions created by the existing regulations, which arbitrarily confine possession ECI from non-USVI sources to certain narrow categories of Section 864(c)(4) income, i.e., rents and royalties for the use of intangible property; interest and divide

would constitute a USVI permanent establishment. Business profits and compensation attributable to such a permanent establishment (whether U.S. or non-USVI source) would be taxable by the USVI under the less restrictive provisions of the Model Treaty. b. Implementing Model Treaty principles in determi

o: Jeffrey E. Subject: <no subject> It appears that if you had the following facts —you will still=not be a resident: 153 in the USVI, 3= non-US/non-USVI and 182 US - you would not be a bona fide resident of the =SVI because the regs state: "The proposed amendment would not =pply, however, if the num