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Virgin Islands Economic Development Commission 
Decision Meeting of Monday, June 8, 2026 
Summary Report 
During the Virgin Islands Economic Development Commission (“VIEDC”) Decision Meeting on 
Monday, June 8, 2026, the Governing Board heard recommendations from the VIEDC Team 
regarding one (1) application matter, and voted as follows: 
Regular Session: 
➢Action Items:
❖
Applications:
▪
CM Sun Operations, Inc. & CM St. Croix Propco, LLP – New Application
CM Sun Operations, Inc. (“CM Sun”), a subsidiary of Club Med. CM St. Croix Propco LLP (“Propco”), a subsidiary 
of VICI Properties Inc. CM Sun and Propco seek Economic Development Commission (“EDC”) benefits as a 
Category III - Hotel/Guesthouse for the purchase and financing, ownership, construction and redevelopment of 
the iconic Carambola Beach Resort located on St. Croix and pursuant to the terms of V.I. Code Ann. tit. 29, § 
708(a)(1) which allows the Commission to grant benefits to other such industries or businesses as may be 
considered appropriate by the Commission and which will advance the economic well-being of the Virgin Islands 
and its people. CM Sun is located on the island of St. Croix.  
CM Sun commits to employing 200 full-time employees. CM Sun also commits to making a minimum capital 
investment of $62,811,776.00 in the benefited business.  CM Sun further agrees to meet all statutory and special 
conditions, and other applicable requirements for the grant of tax incentive benefits. 
The Governing Board voted (6 – 0) to: 
1. THAT Applicant/Beneficiary is deserving of a grant of tax incentives;
2. THAT Applicant/Beneficiary be granted tax exemptions at one hundred
percent (100%) of the incentives authorized by law for a period of 30 years
in accordance with the provisions of V.I. CODE ANN. tit. 29, chapter 12;
3. THAT retail sales, concessions, and rental activities not owned and operated
by Applicant/Beneficiary shall be specifically excluded from tax incentives.
Any revenue from room and board rentals that are not subject to hotel
room tax shall also be excluded from tax incentives.1
4. THAT Applicant/Beneficiary is granted a waiver of the eighty percent (80%)
residency requirement, and, as such, at least sixty-five percent (65%) of all
persons it employs shall be U.S. Virgin Islands residents as defined in 29
V.I.C. § 703(e) commencing with the opening of the resort to December 31,
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Applicant/Beneficiary shall operate as a hotel that shall collect the hotel room tax and shall only take tax exemptions 
on revenues that qualify as revenues from a “guest” as defined in 3 V.I.C. § 54(a)(3).  See Form 722 V.I. (Hotel Room Tax 
Return). 
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2028. At least seventy-five percent (75%) of all persons employed by 
Applicant/Beneficiary shall be U.S. Virgin Islands residents by December 31, 
2029. Applicant/Beneficiary shall comply with the eighty percent (80%) 
residency requirement by December 31, 2031, and not less than twenty 
percent (20%) of management, supervisory and/or technical positions shall 
be held by residents of the U.S. Virgin Islands pursuant to 29 V.I.C. § 710(a). 
Applicant/Beneficiary shall contribute Five Thousand Dollars ($5,000.00) 
annually to the Territorial Scholarship Fund in accordance with 29 V.I.C. § 
710(b) for each non-resident hired below the sixty-five percent (65%) 
resident requirement. 
5. THAT Applicant/Beneficiary shall submit Department of Planning and 
Natural Resources Certificate(s) of Occupancy within 10 calendar days of 
receipt thereof to VIEDC.
6. THAT Applicant/Beneficiary agrees that both parties shall be jointly and 
severally liable for failure to comply with the terms of the VIEDC Certificate 
and any amendments, extensions or modifications thereto.
7. THAT Applicant/Beneficiary shall submit fully executed copies of Triple-Net 
Lease, Hotel Management Agreement, Property Deed and any other 
agreements evidencing ownership and operation of the resort within 10 
calendar days of execution.
8. THAT Applicant/Beneficiary shall comply with the Victims of Trafficking and 
Violence Protection Act of 2000, as may be amended from time to time, 
to combat human trafficking. Applicant/Beneficiary shall provide VIEDC a 
copy of the hotel policy against human trafficking in its Resort within 10 
calendar days of execution. The policy shall be maintained at all times and 
proof that all employees are notified of same upon employment shall be 
submitted to VIEDC annually.
9. THAT Applicant/Beneficiary shall maintain a hotel brand, or brand of 
comparable quality to Club Med St. Croix during the term of incentives and 
require compliance with VIEDC provisions as a condition of any 
management agreement.
10. THAT Applicant/Beneficiary shall ensure it complies with the US Virgin 
Islands minimum wage or occupational wages, for USVI resident and 
nonresident employees. Applicant/Beneficiary shall 
provide 
VIEDC 
certification from the Department of Labor to confirm compliance with 
Labor laws relating to non-USVI resident employee(s) compensation to 
include comparable wages to a VI Resident employee with similar 
employment positions, as applicable.
11. THAT Applicant/Beneficiary shall provide formal written notice of 
employment opportunities to former employees of Davis Bay LLC who were
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separated due to the sale of the Carambola Hotel, within the first year of 
the reopening of the hotel. A copy of said notice and list of former 
employees provided with written notification shall be submitted to VIEDC 
within 10 business days of said notification. 
12. THAT Applicant/Beneficiary shall provide cultural programming and
initiatives, such as culinary, arts, music and entertainment, cultural
education and excursions, and community engagement as described in the
application as a core component of its resort operations and its
commitment to the broader USVI community.
13. THAT VIEDC’s grant of incentives be conditioned upon receipt of favorable
background reports for the following international entities, Fosun Tourism
and Culture Group (HK) Company Limited and Fosun International Limited,
which remain outstanding as of the date and time of this meeting.