The Government's proposal would leave the existing alternative physical presence tests 19 See Letter from USVI Gov. Charles W. Turnbull to The Hon. John W. Snow, Secretary of the Treasury, April 28, 2005. 30 Declaration of Percival Clouden, Appleton v. Comm 'r, No. 7717-10 (Tax Ct. Aug. 18,2010), at 911. 1