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There's a special exception that will allow you to use the Puerto Rico tax benefits immediately upon moving there in certain circumstances, but this exception requires you to live in Puerto Rico for at least 3 years. Then, the capital gain must be Puerto Rican source capital gain.
In the case of long-term capital gains, Puerto Rican non-resident foreign nationals are subject to a flat withholding rate of 25%. Puerto Rican non-resident US citizens are only subject to a flat withholding rate of 15% on long-term capital gains.
While Acts 20 and 22 are only applicable for Puerto Rico income tax purposes, U.S. citizens willing to become bona fide residents of Puerto Rico (implicating IRC §933) stand to benefit tremendously.
Physical Presence: the investor has to be physically present in Puerto Rico 168-183 days per year, and in the United States for less than 90 days in the year. The restrictions may have been modified to require only that the investor have spent more time in Puerto Rico than any other single place in the world.
Act 20, also known as the Export Service Act, targets certain service businesses by offering corporate tax rates as low as 4% to qualifying corporations that relocate to the jurisdiction. Exempt businesses will enjoy a 75% exemption on the municipal and state property taxes.
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Puerto Rico source passive income is completely exempt from federal taxation under IRC §933; however, new qualifying residents may even reduce the tax rate on non-Puerto Rico source passive income to 0% (for interest) and 10% (for dividends) by using Puerto Rico investment vehicles.
Further, Resident Individuals must apply for and obtain a tax exemption decree under Act 60. To obtain access to the approved and signed tax exemption decree, a one-time fee of $5,000 must be satisfied and deposited into a special fund to promote the relocation of Resident Individuals to Puerto Rico.
An individual is considered to be a bona fide resident of Puerto Rico only if he or she satisfies all of the following three conditions: (1) physical presence test, (2) tax home test, and (3) closer connection test. A special rule applies for the year of the move.
Physical Presence: the investor has to be physically present in Puerto Rico 168-183 days per year, and in the United States for less than 90 days in the year. The restrictions may have been modified to require only that the investor have spent more time in Puerto Rico than any other single place in the world.
The Individual Investors Act (Act 22) seeks to attract new residents to Puerto Rico by providing a total exemption from Puerto Rico income taxes on all passive income realized or accrued after such individuals become bona fide residents of Puerto Rico.

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