Puerto Rico Residency Tax Incentives for U.S.-Based Individuals and Businesses
Puerto Rico Act 60, Key Issues for Taxpayers, Navigating IRS Examination and Audits, Tax Planning
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will provide tax advisers guidance on Puerto Rico residency tax benefits and incentives for individuals and businesses and navigating applicable tax rules and IRS examination for Puerto Rico Act 60 grantees. The panel will discuss the potential risks of IRS audits for individuals and businesses taking advantage of U.S. tax incentives for Puerto Rico-sourced income. The panel will also discuss the favorable treatment of capital gains and dividend income and the challenges of relocating to Puerto Rico as an alternative to tax expatriation. The webinar will also detail residency requirements and outline potential caveats to U.S. taxpayers considering a relocation to Puerto Rico for tax purposes.
Outline
- Overview of Puerto Rico Act 60
- IRC provisions specific to Puerto Rico and certain U.S. territories and possessions
- Section 933
- Section 937 special residency rules
- IRS notice requirements
- Establishing residence
- Determining the limits of Puerto Rico-source income
- Likely areas of audit and disagreement
- Caveats
Benefits
The panel will review these and other relevant topics:
- The impact and focus of the IRS audit campaign for Puerto Rico Act 60 grantees
- How Internal Revenue Code provisions and Puerto Rico local tax statutes provide an alternative tax haven to expatriation for certain high net worth taxpayers
- Specifics of Puerto Rico's Act 20 (Export Services Act) and Act 22 (Individual Investors Act) as vehicles for attracting U.S. mainland-based taxpayers to relocate to Puerto Rico
- Timing, notice, and qualification requirements to claim tax benefits
- Best practices to avoid or minimize the chances of being subject to IRS examination
Faculty
Rogelio Carrasquillo
Managing Shareholder
Carrasquillo Law Group
Mr. Carrasquillo has been providing strategic guidance and advice to clients in a variety of complex and... | Read More
Mr. Carrasquillo has been providing strategic guidance and advice to clients in a variety of complex and sophisticated legal transactions for over 20 years. He advises domestic and foreign companies, multinationals, and entrepreneurs on their business activities and investment considerations in the United States and throughout Latin America, Asia, and Europe, including in cross-border transactions.
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Mark H. Leeds
Partner
Pillsbury Winthrop Shaw Pittman
Mr. Leeds focuses his practice on the tax consequences of a variety of financial products and strategies,... | Read More
Mr. Leeds focuses his practice on the tax consequences of a variety of financial products and strategies, including digital assets, private funds, exchange-traded funds, litigation finance, life settlement, banking and insurance. His experience includes both exchange-traded and over-the-counter derivative transactions, and strategies for the efficient utilization of tax attributes—such as net-operating losses. Mr. Leeds regularly works with financial institutions on developing products and the related tax reporting considerations. He also advises businesses and individuals in establishing operations and relocating to Puerto Rico and has a substantial practice in private credit transactions. Mr. Leeds is well-known for his extensive writings on capital markets tax issues.
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Manuel (Nolin) Lopez-Zambrana
Partner
DLA Piper
Mr. López-Zambrana ("Nolin") represents clients in a variety of industries such as financial,... | Read More
Mr. López-Zambrana ("Nolin") represents clients in a variety of industries such as financial, mutual funds, manufacturing, not for-profit, insurance airline transportation, maritime transportation and telecommunications industries. His expertise is highly sought after in all stages of tax controversies. Mr. Lopez-Zambrana is considered by Chambers and Partners publication as a "standout tax practitioner who receives glowing recommendations from sources as one of the leading lawyers in the field." He also advises clients on complex US federal and PR income tax matters and assists them with obtaining PR tax incentives for manufacturing and IP licensing activities, qualified energy activities, export services and foreign trade activities, individual resident investors, among others.
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Cannot Attend November 11?
Early Discount (through 10/17/25)
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.
