Research the topic “Puerto Rico as a Domestic Tax Haven: Relocating as an Alternative to Expatriation to Claim Income Tax Savings” .
With the enhanced focus on offshore tax avoidance, it is ironic that one of the world’s last remaining tax havens is a U.S. possession, namely the Commonwealth of Puerto Rico. Both the Internal Revenue Code and Puerto Rican tax laws provide significant tax minimization opportunities for high net worth individuals and business owners to relocate to the island.
IRC Section 933 exempts bona fide residents of Puerto Rico from U.S. federal income tax on any Puerto Rico-sourced income. As a further sweetener, Section 937 sets the threshold for establishing bona fide residency in Puerto Rico (and some other U.S. possessions) at 183 days, which are more favorable terms than residency rules for offshore non-U.S. jurisdictions.
In addition to the IRC provisions, Puerto Rico has enacted several tax provisions designed to attract investors and business owners to relocate to the island. The two key provisions are Act 20 (Export Services Act) and Act 22 (Individual Investors Act). Act 20 sets a maximum income tax rate of 4% on the net profits of any business exporting services from Puerto Rico to companies or individuals outside the island. Act 22 exempts from income tax all passive income derived by bona fide residents of Puerto Rico and follows IRC 933 in setting the threshold for residency at 183 days.
Write about these rules, who might best benefit from them, how they would benefit, and think of some tax planning tips you could give to your clients or employer based on this information.
Attach your Word document here. Use APA format, double-space, 12-point font, no more than five pages, and cite sources for the information document. Then arrange your findings into bullet points in PowerPoint using no more than 3 slides to summarize.
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