Puerto Rico's Act 60 offers the most aggressive legal tax optimization available to US citizens. A 4% income tax rate. Zero capital gains. Contractually guaranteed through 2055. We guide you through every detail.
Reduce your effective tax rate from 37%+ to 4% on eligible business income. Legally. For the duration of your 15-30 year decree.
Eliminate capital gains tax on post-move investments. Applications filed before December 31, 2026 are grandfathered at 0%.
Your decree is a binding contract with Puerto Rico. It cannot be revoked unilaterally. Extended through 2055 with long-term certainty.
Designed for individuals with significant investment income. Qualifying recipients receive 100% exemption from Puerto Rico income tax on capital gains, dividends, and interest earned after establishing residency.
For businesses providing services to clients outside Puerto Rico. The corporate tax rate drops to 4%, with 0% tax on distributions to PR-resident shareholders.
Pre-move appreciation on marketable securities remains subject to US capital gains tax. Post-move appreciation qualifies for favorable PR treatment. After 10 years of continuous bona fide residency, all gains — including pre-move appreciation — become Puerto Rico-source.
The IRS applies a three-part test: physical presence (183+ days), tax home (principal place of business in PR), and closer connection (social, financial, and residential ties stronger to PR than any other jurisdiction). Documentation is critical. We help you build an audit-proof record from day one.
We work with individuals and families for whom tax optimization is not a strategy — it is a necessity.
Structured Act 60 entities that protect family wealth across generations. Coordinated with estate planning, trust structures, and ongoing compliance.
Restructure your compensation as export services. Transition from employee to consultant. 4% on your income instead of 37%+.
Real estate, equities, private equity, cryptocurrency. All post-move gains qualify for 0% treatment under Chapter 2.
Relocate your portfolio, eliminate capital gains on future growth, and enjoy a Caribbean lifestyle with full US infrastructure and protections.
A disciplined, five-phase process designed for clients who expect precision.
We evaluate your income sources, business structure, investment portfolio, and relocation feasibility. Complete confidentiality.
Our legal and CPA partners design your optimal Act 60 structure. Entity selection, chapter alignment, timeline planning.
Complete decree application preparation, entity formation, EIN filing, DEDC submission, and government liaison through approval.
Curated introductions to real estate specialists, banking relationships, utility coordination, and community integration.
Annual monitoring, compliance report filing, residency tracking, and CPA coordination for the life of your decree. Peace of mind for 15-30 years.
Applications filed before December 31, 2026 are grandfathered at 0% on passive income. After this date, new applicants receive a 4% rate — still highly favorable, but the window for zero is closing.
One relationship. A complete team of specialists.
Puerto Rico-based attorneys specializing in Act 60 entity formation, decree applications, and ongoing legal compliance
Certified public accountants with deep Act 60 and Puerto Rico tax experience — planning, compliance, and audit preparation
Curated introductions to luxury specialists in Dorado, Condado, and San Juan who understand the Act 60 property requirement
Yes. Act 60 is Puerto Rico law, enacted in 2019 and extended through 2055. It operates under IRC Section 933, which exempts Puerto Rico-source income from US federal taxation. The program was designed to attract capital and talent to the island. Over 4,000 individuals hold active decrees. The IRS is fully aware of the program and audits it — which is precisely why compliance matters.
Three tests must be met simultaneously: (1) Physical presence of 183+ days per year in Puerto Rico, (2) your tax home — principal place of business — must be in Puerto Rico, and (3) you must demonstrate a closer connection to Puerto Rico than to any other jurisdiction. The IRS evaluates 11 factors including driver's license, voter registration, banking, social affiliations, and family location. We help you build an audit-proof record.
For marketable securities (stocks, bonds), gains are split: pre-move appreciation remains subject to US capital gains tax, while post-move appreciation is Puerto Rico-source and tax-free. After 10 years of continuous bona fide residency, all gains — including pre-move appreciation — become PR-source. For non-marketable assets (private company interests, real estate), a days-of-ownership allocation method applies.
You may own property on the mainland, but your primary residence, tax home, and closer connection must be in Puerto Rico. You can travel to the mainland for business and personal reasons — you simply cannot exceed 182 days there per year. Detailed travel records are essential.
The US government does not allow you to avoid tax on appreciation that occurred before your move. The 10-year lookback rule splits gains accordingly. However, new acquisitions made after establishing residency qualify for full Act 60 benefits from day one. Strategic timing of asset sales is a critical part of the planning process.
Act 60 can be integrated with your estate plan. PR-based trusts and entities can hold decree benefits. Our legal partners coordinate with your existing estate attorneys to ensure seamless integration. The 0% dividend and capital gains rates can significantly enhance intergenerational wealth transfer strategies.
Government fees: $5,005 application fee (one-time), $5,005 annual compliance fee, $10,000 annual charitable donation. Our advisory fees: from $7,995 for the full application. Legal and CPA partners charge separately, typically $5,000–$15,000 combined. Most clients recover the entire cost within their first month of tax savings.
Your tax decree is a binding contract between you and the Puerto Rico government. It cannot be revoked or modified unilaterally — even if Act 60 were repealed entirely. This contractual protection is written into the statute itself. Existing decree holders retain their benefits for the full term, which can extend through 2055.
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