US VIRGIN ISLANDS Trends and Developments Contributed by: Marjorie “Jorie” Roberts, Sean Foster, Alexander Polinsky and Duncan J. J. Kessler, Marjorie Rawls Roberts P.C.
Marjorie Rawls Roberts P.C. 5093 Dronningens Gade Suite 1 St. Thomas VI 00802 US Virgin Islands
Tel: +340 776 7235 Fax: +340 776 7951 Email: jorie@mrrvilaw.com Web: www.mrrvilaw.com
An Overview of Private Wealth in the United States Virgin Islands The United States Virgin Islands (USVI) offers unique opportunities for private wealth planning for US citi - zens and tax residents through its economic devel - opment programmes. These focus in large part on providing tax incentives to family offices, investment managers and advisers, and to businesses engaged in venture capital management and investments as well as investment banking and financial services. In addition, the USVI offers targeted incentives for com - mercial trade and investment as well as manufactur - ing, thus offering support to investors who seek to optimise tariff planning. The USVI also provides significant benefits for non-US citizens who have substantial assets outside the USA but who seek to obtain US citizenship. By becoming naturalised in the USVI, new US citizens can structure their holdings to avoid US estate and gift tax on any non-US situs assets, including the assets they held at the time of naturalisation. Further, the USVI uses the Internal Revenue Code of 1986, as amended, as its tax code (the “Code”) so that the recently enact - ed benefits for high net worth individuals in the One Big Beautiful Bill Act (OBBBA), as signed into law by President Trump on 4 July 2025, also apply to USVI residents when filing their tax returns with the USVI Bureau of Internal Revenue (BIR). Finally, the USVI is the only US jurisdiction where for - eign shareholders can set up exempt companies to hold their assets worldwide and obtain tax exemp - tions on all the income earned from investments
(other than income from US sources) while obtaining the benefits of the US flag, the US investment treaty network and the US banking system. This article will discuss each of the benefits in turn after providing a brief background on the USVI. Background and tax system overview The USVI is an unincorporated territory of the USA located approximately 1,100 miles south-east of Miami, Florida. Acquired from Denmark in 1917, the USVI is made up of the islands of St Croix, St John, St Thomas and Water Island, along with numerous unin - habited cays, with a total population of approximately 85,000. The USVI uses US currency, and no exchange controls exist. The USVI’s prime natural resources include pristine beaches, crystal-clear seas, a mild year-round cli - mate, the natural harbour on St Thomas, the Virgin Islands National Park on St John and the rainforest on St Croix. These assets, combined with the investment security of a US jurisdiction and a variety of federal and local incentives, have cemented tourism as the major local economic activity. The USVI also offers banks that are FDIC-insured, and is covered by the USA’s extensive network of bilateral investment treaties (but not tax treaties). The USVI has two federal judges and is part of the Third Circuit Court of Appeals. It has direct flights to many main - land cities and attracts many yachts seeking a secure, well-located home base.
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