puerto rico as a domestic tax haven: relocating as an...
TRANSCRIPT
WHO TO CONTACT DURING THE LIVE PROGRAM
For Additional Registrations:
-Call Strafford Customer Service 1-800-926-7926 x1 (or 404-881-1141 x1)
For Assistance During the Live Program:
-On the web, use the chat box at the bottom left of the screen
If you get disconnected during the program, you can simply log in using your original instructions and PIN.
IMPORTANT INFORMATION FOR THE LIVE PROGRAM
This program is approved for 2 CPE credit hours. To earn credit you must:
• Participate in the program on your own computer connection (no sharing) – if you need to register
additional people, please call customer service at 1-800-926-7926 ext. 1 (or 404-881-1141 ext. 1).
Strafford accepts American Express, Visa, MasterCard, Discover.
• Listen on-line via your computer speakers.
• Respond to five prompts during the program plus a single verification code.
• To earn full credit, you must remain connected for the entire program.
Puerto Rico as a Domestic Tax Haven: Relocating as an
Alternative to Expatriation to Claim Income Tax SavingsWEDNESDAY, AUGUST 28, 2019, 1:00-2:50 pm Eastern
FOR LIVE PROGRAM ONLY
Tips for Optimal Quality FOR LIVE PROGRAM ONLY
Sound Quality
When listening via your computer speakers, please note that the quality
of your sound will vary depending on the speed and quality of your internet
connection.
If the sound quality is not satisfactory, please e-mail [email protected]
immediately so we can address the problem.
August 28, 2019
Puerto Rico as a Domestic Tax Haven: Relocating as an Alternative to Expatriation to Claim Income Tax Savings
K. Eli Akhavan, Chair, Private Clients and
Wealth Preservation Group
CKR Law
Gabriel Hernández, CPA, Partner
BDO
Robert W. Wood, Managing Partner
Wood LLP
Notice
ANY TAX ADVICE IN THIS COMMUNICATION IS NOT INTENDED OR WRITTEN BY
THE SPEAKERS’ FIRMS TO BE USED, AND CANNOT BE USED, BY A CLIENT OR ANY
OTHER PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT
MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR
RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN.
You (and your employees, representatives, or agents) may disclose to any and all persons,
without limitation, the tax treatment or tax structure, or both, of any transaction
described in the associated materials we provide to you, including, but not limited to,
any tax opinions, memoranda, or other tax analyses contained in those materials.
The information contained herein is of a general nature and based on authorities that are
subject to change. Applicability of the information to specific situations should be
determined through consultation with your tax adviser.
PUERTO RICO TAX INCENTIVES
Gabriel HernándezTax Advisory PartnerBDO Puerto Rico
ABOUT GABRIEL HERNÁNDEZ
Gabriel Hernández, CPAPartner
Tax Advisory Services
US & Puerto Rico Tax Consulting Expert with
more than 25 years of experience
Active promoter of Puerto Rico’s economic development efforts
Founding member of “Puerto Rico is the Answer” Action Tank
MIT Regional Entrepreneurship Acceleration Program Puerto Rico Cohort
Head of the Tax Division at BDO in Puerto Rico
Head of Tax of the Caribbean for BDO International
Areas of expertise: tax planning, structuring and exemption packages under the various
tax incentive laws available in P.R.
BDO is the 5th largest global accounting firm with over 1,400 offices and 80,000
employees throughout the world.
6
AGENDA
Act 20
Act 22
Other Tax Incentives
ACT 20/22 BDO Methodology
7
TAX INCENTIVES TO PROMOTE EXPORT SERVICES IN PUERTO RICO
* For certain eligible activities
ACT 20
Eligibility
The Act provides benefits for services provided from Puerto Rico to outside markets.
8
TAX INCENTIVES TO PROMOTE EXPORT SERVICES IN PUERTO RICO
Puerto Rico Businesses:
The Act applies with respect to any entity with a bona fide office or establishment
located in Puerto Rico that is or may be engaged in an eligible service.
Services for Exportation:
Services must be performed for non-resident individuals and/or foreign entities that
have no nexus with Puerto Rico.
ACT 20 – REQUIREMENTS
9
ABOUT ACT 22
10
TAX INCENTIVES TO ATTRACT INVESTORS TO PUERTO RICO
Eligibility
Bona-fide residents of Puerto Rico who had established residence during the 6-year
period preceding the enactment of the Act on January 12, 2012
Meeting the tests prescribed in the IRC Regulation 1.937-1:
– (1) is present in PR for at least 183 days
– (2) does not have a tax home outside of PR and
– (3) has a closer connection to Puerto Rico
Up to December 31, 2035
ACT 22
11
TAX INCENTIVES TO ATTRACT INVESTORS TO PUERTO RICO
ACT 22
12
OTHER TAX INCENTIVES
OTHER TAX INCENTIVES
Incentive for the Development of Puerto Rico
Known as the Economic Incentives Act for the Development of Puerto Rico, Act. No. 73
was established to provide the adequate environment and opportunities to continue
developing a local industry, offer an attractive tax proposal, attract direct foreign
investment and promote economic development and social betterment in Puerto Rico.
PUERTO RICO ECONOMIC DEVELOPMENT PROGRAM
15
OTHER TAX INCENTIVES
Private Equity Incentive
By promoting this investment vehicle used
by investors around the world, Act No. 185
promotes the creation of jobs for
professionals in the field of securities and
financial business in Puerto Rico, as well as
the development of the securities industry
on the Island.
Incentive for Financial Institutions
Act No. 273 regulates the organization and
operation of international financial
institutions authorized by the Office of the
Commissioner of Financial Institutions to
operate in Puerto Rico, and grants tax
exemption decrees, among other benefits.
PUERTO RICO ECONOMIC DEVELOPMENT PROGRAM
16
OTHER TAX INCENTIVES
Incentive for International Insurers and Reinsurers
Act No. 399 allows companies to organize a captive insurance in Puerto Rico and may
incorporate a holding company for the interest in another company. Tax exemptions for
insurers that qualify for an international insurer license are 100% exempt on all income,
including liquidation and dissolution of its operations in Puerto Rico.
Tourism Development Incentive
Act No. 74 offered through the Puerto Rico Tourism Company provides incentives for the
development of a world-class tourist industry. Act 74 is most commonly used by large hotel
projects.
PUERTO RICO ECONOMIC DEVELOPMENT PROGRAM
17
OTHER TAX INCENTIVES
PUERTO RICO ECONOMIC DEVELOPMENT PROGRAM
The New Puerto Rico Tax Incentives Code, Act 60 of July 1, 2019, codified and modified
tax incentives available in Puerto Rico under several tax incentives laws including Act 20
and 22 of 2012. Some of the changes include:
18
ACT 20/22 BDO METHODOLOGY
20
ACT 20/22 BDO METHODOLOGY
21
