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
A live 90-minute premium CLE/CPE video webinar with interactive 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
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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Cannot Attend May 13?
Early Discount (through 04/18/25)
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.