Sesenta Global — Strategic Tax Optimization Through Puerto Rico Act 60

Q: What constitutes bona fide residency in Puerto Rico?

Three tests must be met simultaneously: physical presence of 183+ days per year in Puerto Rico, your tax home must be in Puerto Rico, and 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, and family location.

Q: How does the 10-year lookback rule work?

For marketable securities, 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.

The Jurisdiction

The Island Decision

Before the tax code, families evaluate the island itself. The case is stronger than most realize.

US Jurisdiction

Puerto Rico operates under the US flag, the US dollar, and US federal law. Your assets sit inside the American banking system, with FDIC-insured accounts and access to federal courts. The legal framework protecting your wealth is the one you already know.

Opportunity & Infrastructure

Direct flights connect San Juan to every major US hub in under three hours — Miami in forty-five minutes. Federal infrastructure investment continues to flow into the island, and nearly the entire territory qualifies for Opportunity Zone treatment. Over 4,000 decree holders have already made this move.

III

Talent & Community

A fully bilingual, US-educated workforce anchored by more than 80 universities and colleges. The island has spent six decades building a bioscience and manufacturing base that draws global companies — and the families behind them. You are not moving to the margin of the US economy. You are moving to a hub.

The Life

Year-round Caribbean climate, private international schools, championship golf and tennis, and a dining scene that has drawn global attention. For families relocating under Chapter 2, the residential property purchase within two years becomes not a compliance burden but the beginning of the life you came for.

Institutional Depth

Why Global Operators Are Already Here

80+

Universities and colleges across the island

100%

Bilingual professional workforce

60 yrs

Of continuous bioscience and manufacturing base

~100%

Of the territory eligible for Opportunity Zone treatment

As a U.S. jurisdiction with a competitive tax framework and a highly skilled workforce, Puerto Rico is strengthening its ability to attract capital, entrepreneurs, and businesses looking to invest and grow for the long term.

The Governor of Puerto Rico

On the occasion of the New York Stock Exchange welcoming the Puerto Rico delegation — commemorative NYSE Coin presented by Will Goodwin, Director of Corporate Affairs, NYSE.

Understanding Act 60

A Sophisticated Tax Strategy

Act 60 of the Puerto Rico Incentives Code consolidates two powerful programs into a single framework. Here is what you need to understand.

Chapter 2 — Individual Resident Investor

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.

0% tax on long-term and short-term capital gains on PR-source income
100% exemption on dividend and interest income
Must become a bona fide resident: 183+ days, tax home, closer connection
Purchase residential property in PR within two years
$10,000 annual charitable donation requirement
$5,005 application fee; $5,005 annual compliance fee

Chapter 3 — Export Services

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.

4% corporate tax rate on eligible export service income
0% tax on dividend distributions
75% property tax exemption; 50% municipal tax exemption
80%+ of revenue must come from services to non-PR clients
Qualifying: consulting, technology, finance, legal, creative, engineering
15-year decree with possible 15-year extension

The 10-Year Lookback Rule

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.

Residency Requirements

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.

Clientele

Who We Serve

We work with individuals and families for whom tax optimization is not a strategy — it is a necessity.

◆

Family Offices

Multi-generational wealth preservation

Structured Act 60 entities that protect family wealth across generations. Coordinated with estate planning, trust structures, and ongoing compliance.

◆

Senior Executives

Transition from W-2 to advisory

Restructure your compensation as export services. Transition from employee to consultant. 4% on your income instead of 37%+.

◆

Investors

Zero tax on future gains

Real estate, equities, private equity, cryptocurrency. All post-move gains qualify for 0% treatment under Chapter 2.

◆

Retiring Professionals

Preserve wealth in retirement

Relocate your portfolio, eliminate capital gains on future growth, and enjoy a Caribbean lifestyle with full US infrastructure and protections.

Methodology

Our Approach

A disciplined, five-phase process designed for clients who expect precision.

Private Assessment

We evaluate your income sources, business structure, investment portfolio, and relocation feasibility. Complete confidentiality.

Strategic Planning

Our legal and CPA partners design your optimal Act 60 structure. Entity selection, chapter alignment, timeline planning.

III

Application Management

Complete decree application preparation, entity formation, EIN filing, DEDC submission, and government liaison through approval.

Relocation Concierge

Curated introductions to real estate specialists, banking relationships, utility coordination, and community integration.

Ongoing Compliance

Annual monitoring, compliance report filing, residency tracking, and CPA coordination for the life of your decree. Peace of mind for 15-30 years.

Where Our Families Live

The Island, Not the Brochure

Chapter 2 requires a residential property purchase within two years of your decree. Our clients treat that requirement as strategy — choosing the island neighborhood that fits the family.

Dorado

North Coast — 25 min from San Juan

The established decree-holder enclave. Gated communities, championship golf, private beach clubs, and the international school corridor. Where most Chapter 2 families begin their search.

Fits: families prioritizing schools, golf, and an established expat community

Condado & Old San Juan

Metro San Juan — walkable waterfront

Oceanfront high-rises, hotel dining, and the historic district at your doorstep. Condado is the default for executives who want city convenience with a beach address; Old San Juan for those who want three centuries of architecture outside the window.

Fits: executives and couples who want walkability and a short commute

Palmas del Mar

East Coast — Humacao

A self-contained resort community on the eastern coast: marina, equestrian center, two golf courses, and its own school inside the gates. The island's most complete planned community, an hour from the capital.

Fits: families wanting resort amenities and a built-in community from day one

Rincon Puerto Rico west coast surfer town sunset

Rincón

West Coast — surf country

The west coast's laid-back counterweight. World-class surf, sunset views, and a tight-knit American community drawn by the lifestyle rather than the tax code. A deliberate choice for families who want the island at its most unhurried.

Fits: lifestyle-first families, surf and sunset people

We advise on where the requirement fits your strategy. We are advisors, not brokers — no listings, no referral arrangements.

Engagement

Engagement Tiers

Consultation

Complimentary

No obligation

Private assessment of eligibility
Personalized savings projection
Chapter alignment recommendation
Timeline and next steps

Start a Conversation

Full Advisory

From $7,995

One-time engagement

Complete decree application
Entity structuring and formation
Legal and CPA coordination
DEDC filing and government liaison
Document preparation and tracking
Relocation guidance

Begin Engagement

Concierge

Custom

Tailored to your needs

Full Advisory included
Relocation concierge services
Real estate introductions
Family office coordination
Ongoing advisory relationship
Priority access to partners

Discuss Your Needs

Annual Compliance:$2,495/year — Continuous monitoring and compliance for the life of your decree

Questions

Frequently Asked

Is Act 60 legally defensible?▼

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.

What constitutes bona fide residency?▼

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.

How does the 10-year lookback rule work?▼

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.

Can I maintain a mainland residence?▼

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.

What about existing unrealized gains?▼

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.

How does this interact with estate planning?▼

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.

What is the total cost including government fees?▼

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.

What happens if Puerto Rico changes the law?▼

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.

Strategic Tax Optimization for Discerning Individuals and Families

Three Pillars of Act 60