Twin Palms Resort, LLC Ex Rel. Harbour v. United States

ORDER GRANTING MOTION FOR SUMMARY JUDGMENT AND DENYING PETITION TO QUASH

PAUL C. HUCK, District Judge.

I. BACKGROUND

A. Virgin Islands Tax Scheme

In 1960, apparently in an effort to spur economic development in the United States Virgin Islands, Congress authorized preferential tax treatment for residents of the Virgin Islands. 26 U.S.C. § 934 allows the Virgin Islands to reduce its income tax for bona fide residents with respect to income derived from sources in, or effectively connected with the conduct of a trade or business in, the Virgin Islands. In response, the Virgin Islands created the…