Puerto Rico Act 60: 4% Capital Gains, Bona Fide Residency & IRS Rules

4% Capital Gains • 0% Dividends & Interest • 183-Day Presence • Form 8898 • IRS Scrutiny High
IRC §933IRC §937PR Act 60-2019 Chapter 2
← Individual Tax

Puerto Rico Act 60 (formerly known as Acts 20 and 22) offers US citizens who establish bona fide Puerto Rico residency a 4% flat tax rate on net capital gains and 0% on dividends and interest - provided those gains arise after the individual becomes a bona fide Puerto Rico resident. For a high-net-worth individual with concentrated stock positions or a cryptocurrency portfolio with large unrealized gains, the potential tax savings from Act 60 are substantial. But the IRS actively audits Act 60 participants, the residency requirements are strict, and the tax benefits apply only to income sourced to Puerto Rico after residency is established - not to pre-move appreciation.

What Act 60 Chapter 2 Provides

4% flat tax on capital gains: Long-term capital gains recognized by a bona fide Puerto Rico resident from assets acquired after establishing residency are taxed at 4% by Puerto Rico. These gains are excluded from US federal income tax under IRC §933 if properly sourced to Puerto Rico.

0% on dividends and interest: Dividends and interest from Puerto Rico sources received by a bona fide Act 60 resident are exempt from Puerto Rico tax and excluded from US federal income tax under §933.

Annual requirements: $10,000 charitable contribution to Puerto Rico-based charities; maintain bona fide Puerto Rico residency for the full tax year; file Puerto Rico income tax return; comply with all reporting obligations including IRS Form 8898.

Bona Fide Residency: The Three-Part Test

To qualify for Act 60 benefits, a US citizen must be a bona fide resident of Puerto Rico. Bona fide residency under IRC §937 requires meeting all three of the following tests:

Presence test: The individual must be present in Puerto Rico for at least 183 days during the tax year. The IRS also uses a "closer connection" analysis - the individual's tax home must be Puerto Rico, and they cannot have a closer connection to the US or another foreign country.

Tax home test: The individual's tax home (regular or principal place of business) must be in Puerto Rico. Remote workers who maintain US clients and US business ties face scrutiny on this requirement.

Closer connection test: The individual must not have a closer connection to the US than to Puerto Rico. The IRS examines: where the family home is, where the family lives, where social and professional connections are centered, where personal property is located, and where professional licenses are maintained.

The IRS has made Act 60 compliance a priority examination area. The IRS has dedicated resources specifically to auditing Act 60 participants, focusing on whether residency is genuine or merely nominal. Individuals who spend most of their time in the continental US, maintain strong US social and professional ties, and visit Puerto Rico only to satisfy minimum presence requirements are the primary audit targets. The IRS has successfully challenged Act 60 residency claims where participants failed the closer connection test despite technically meeting the 183-day presence requirement.

The Pre-Move Appreciation Problem

Act 60 benefits apply only to gains from assets acquired after establishing Puerto Rico residency. A US investor who holds $5 million of Apple stock with a $500,000 basis does not escape federal capital gains tax by moving to Puerto Rico and then selling. The $4.5 million of pre-move appreciation remains US-sourced income fully subject to federal capital gains tax. Only appreciation that accrues after the move - from assets the individual acquires as a Puerto Rico resident, or from the continued appreciation of existing assets after the residency date - benefits from the Act 60 rate.

Planning opportunity: assets with embedded gains should ideally be sold before the move (paying federal tax at 20-23.8%) if the post-move appreciation is expected to be significant, OR held until Puerto Rico residency is established and sold after the move with only post-residency gains taxed at 4%.

Form 8898 and Reporting Requirements

Under IRC §937 and its regulations, a US citizen who becomes a bona fide resident of Puerto Rico must file Form 8898 (Statement for Individuals Who Begin or End Bona Fide Residence in a US Possession) with their federal tax return for the year they establish or terminate Puerto Rico residency. Failure to file Form 8898 when required carries a $1,000 penalty per year of failure. Act 60 residents must also file Puerto Rico income tax returns and pay the 4% Act 60 rate to Puerto Rico on qualifying income.

Authority: IRC §933 (income from sources within Puerto Rico - bona fide resident of Puerto Rico may exclude Puerto Rico source income from US gross income; applies to Act 60 qualifying income once properly sourced to Puerto Rico); IRC §937 (residence and source rules for possessions - bona fide resident defined; three-part test: presence, tax home, and closer connection; Form 8898 reporting requirement); Treas. Reg. §1.937-1 (bona fide resident rules - 183-day presence test; closer connection factors; tax home definition; applies to Puerto Rico and other US possessions); PR Act 60-2019 Chapter 2 (Individual Investors Act - formerly Acts 22 and 20; 4% flat rate on net capital gains from Puerto Rico sources; 0% on dividends and interest; $10,000 annual charitable contribution requirement; annual report filing with Puerto Rico Treasury); Form 8898 (Statement for Individuals Who Begin or End Bona Fide Residence in a US Possession - filed with Form 1040 for year of move; $1,000 penalty per year for failure to file); IRS Examination Priority (IRS Large Business and International division designated Act 60 compliance as priority audit area; focus on closer connection test and source of income rules; pre-move appreciation not protected); Rev. Rul. 2004-4 (source rules for gain on sale of personal property by Puerto Rico residents - gain on property acquired before becoming PR resident has US source to extent of pre-residency appreciation; only post-residency appreciation excluded under §933).