Puerto Rico Act 60 Tax Exemptions: IRS Examination and Audits, Key Issues for Individual and Business Taxpayers
Treatment of Puerto Rico-Sourced Income, Puerto Rico Act 60 (formerly Act 20 and Act 22) Benefits, Residency Requirements
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide persons who have taken advantage of Puerto Rico Act 60 (formerly Act 20 and 22) and their tax advisers with guidance on managing an IRS examination and audit on grantees. The panel will also discuss the favorable treatment for Puerto Rico-source income and areas of likely scrutiny that will inform the IRS audit initiative. The webinar will also detail residency requirements and outline potential caveats to U.S. taxpayers considering relocation to Puerto Rico for tax purposes.
Outline
- IRS audit campaign key areas of focus
- Managing an IRS audit
- 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 20 and 22 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 of Act 22
- Best practices to avoid or minimize the chances of being subject to IRS examination
Faculty
Mark H. Leeds
Partner
Mayer Brown
Mr. Leeds focuses his practice on the tax consequences of a variety of capital markets products and strategies. He... | Read More
Mr. Leeds focuses his practice on the tax consequences of a variety of capital markets products and strategies. He advises on the tax aspects of capital markets, structured finance, derivatives, financial products and insurance transactions and has extensive experience working with both buyers and sellers to develop and structure complex derivatives. A significant portion of his work involves the taxation of financial products and trading strategies engaged in by banks and other financial market participants.
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Juan F. Lopez Valek
Attorney
Mayer Brown
Mr. Lopez Valek is a member of the Tax Transactions & Consulting practice. His practice is focused on corporate tax... | Read More
Mr. Lopez Valek is a member of the Tax Transactions & Consulting practice. His practice is focused on corporate tax matters and advising clients on the tax aspects of mergers and acquisitions, financing arrangements and the formation and investment activities of private funds. Prior to joining Mayer Brown, Mr. Lopez Valek worked as a senior tax associate in a public accounting firm based in New York.
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