In this post, I look at the recent US Tax Court Case Tice v IRS (April 10, 2023). This USVI case has major implications for those of us living and working in Puerto Rico under Acts 20, 22, and 60 (the more recent version of the law). Anyone in Puerto Rico using these tax decrees
In this post, I’ll look at why international banks in Puerto Rico are in the Pandora Papers. While the left-leaning journalists try to spin these banks as somehow sinister, the truth is much more mundane. Here’s what you need to know about why Puerto Rico banks are in the Pandora Papers. The Pandora Papers dwarf
If you operate a successful and portable business, you might consider relocating to Puerto Rico for the tax benefits under Act 60. This article will consider Puerto Rico’s Act 60 and how it might benefit you, the US entrepreneur operating a business that can be relocated. The three criteria for Puerto Rico’s Act 60 are:
In this post, I’ll review the Tier 1 capital you should have at the ready before filing an application for a new bank license, or before attempting to purchase a bank, in the US territory of Puerto Rico. That is, I will consider the Puerto Rico bank capital requirements for 2022 and not the misinformation
In this post, I will consider whether to live abroad and take the foreign earned income exclusion to save on US taxes or to live in the US territory of Puerto Rico. Both Puerto Rico and the foreign earned income exclusion are great tools for reducing your US tax bill. But, which one is right
In order to form a new offshore bank in Puerto Rico, also referred to as an International Financial Entity (IFE), you will need to submit a number of documents to government regulators. Here’s a brief summary of the process to start a bank in Puerto Rico. The process to start a bank in Puerto Rico
It appears that Trump’s tax plan is bringing big changes to Puerto Rico’s Act 20 tax incentive program. These changes impact Puerto Rico because a PR corporation is treated as a foreign corporation for US purposes. Here are the changes coming to Puerto Rico’s Act 20 tax incentive program. Note that this article is a
This article considers Intergovernmental Agreements (IGAs) and Puerto Rico international banks. These entities are also referred to as offshore banks in Puerto Rico and International Financial Entities in Puerto Rico. This post does not consider fully licensed local banks, only how IGAs relate to IFEs operating under Act 273 as an offshore or international bank.
Puerto Rico residents are receiving relief in all forms. For example, Banco Popular has put a hold on lease and mortgage payments for 3 months and others are following suite. Moreover, the IRS issued a letter ruling regarding to residency in the territories and meeting physical presence test under section 937(a). Section 937(a) of the
The entire island of Puerto Rico has been declared a disaster zone by FEMA and power may be out for months. A major dam is failing, which will further reduce available drinking water. How will Hurricane Maria affect those in the Puerto Rico on Act 20 and Act 22? How will this affect your 183
Puerto Rico suffered the worst hurricane to hit the island in 100 years on September 20, 2017. Hurricane Maria destroyed Puerto Rico. So what’s next for the territory of 3.5 million US citizens? Where does Puerto Rico go from here and what about it’s unique tax incentive programs? The US territory of Puerto Rico was
This article is to clear up issues concerning employment and payroll under the tax incentive programs in Puerto Rico. These requirements for the tax incentive programs are to be used in determining how much salary you must take (taxed at ordinary rates) vs. how much corporate profits the entity can make (taxed at 4%). Keep
An international bank licensed in Puerto Rico must comply with all US compliance requirements. All Puerto Rico Act 273 banks must keep detailed records of account holders, and comply with all Know Your Customer (KYC) and Anti Money Laundering (AML) rules. In a recent post on Bloomberg, the author implies that non-US persons can open
Below is an updated review of Puerto Rico’s tax incentives for 2017. Major changes were made to Act 20 and Act 22 on July 11, 2017 (the most popular of Puerto Rico’s tax incentives). In addition, some of the tax incentives have been added and others have been amended. Below is a complete list of
Puerto Rico has opened up its Act 20 program by eliminating the 5 employee requirement. Any US citizen can now move to Puerto Rico, set up a business under Act 20, and pay only 4% in corporate tax. By eliminating the 5 employee requirement for Act 20 businesses, Puerto Rico has opened the floodgates. Note
On July 11, 2017, major changes to Puerto Rico’s Act 20 and 22 were approved. These changes make it much easier to qualify for Puerto Rico’s Act 20 tax holidays. Here’s everything you need to know about the changes to Puerto Rico’s Act 20 and Act 22. As of July 2017, Puerto Rico has a
The US territory of Puerto Rico is going through some tough times and will enter bankruptcy in the next few months. Puerto Rico is set to become the largest bankruptcy case in the history of the American public bond market. Here’s how you and your business can benefit from Puerto Rico’s bankruptcy. Puerto Rico plans
An International Financial Entities licensed in Puerto Rico under Act 273 is one of the most powerful international banking and financial services structures available. As the rules continue to tighten around offshore transactions, offshore tax benefits are reduced under President Trump, and the US increases FATCA and other regulations, expect more financial services companies to
The best tax deal available to hedge fund traders and investment fund managers is Puerto Rico. There’s no tax holiday available anywhere in the world that can compete with the offer from Puerto Rico. Here’s how to setup and operate an investment fund tax free from Puerto Rico. First, let me explain why Puerto Rico
Puerto Rico has the best tax deals available to Americans… period. No offshore jurisdiction can compete with the US territory of Puerto Rico when it comes to cutting your taxes. This post will focus on Puerto Rico’s research and development and intangible property tax breaks. Act 73 is for those who develop licensed or patented