The purpose of this memorandum is to review certain reporting and disclosure requirements, and certain restrictions that may limit the disposition of securities of the company held by its officers, directors and principal shareholders, which are imposed by the Securities Act of 1933, the Securities and Exchange Act of 1934, and the rules of the Securities and Exchange Commission thereunder. This memorandum is prepared for the management of the company and should be treated as a confidential communication between the company and its counsel.
Puerto Rico Limitation on Disposition of Securities Memorandum
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IRS Publication 570 specifically states, ?If all of your income is from Puerto Rico sources, you are not required to file a U.S. tax return.? Publication 570 goes on to state that if a bona fide resident of Puerto Rico has other income, (s)he must file a ?U.S. tax return reporting income from worldwide sources, but ...
Statute of limitations The PRTD generally has four years after an original return is filed to assess income, payroll, and sales and use taxes. A return will be deemed to have been filed on the later of (i) its due date or (ii) the date the return was actually filed.
In addition to being in Puerto Rico for 183 days, you must also pass two additional tests: You must not have a ?tax home? outside of Puerto Rico at any point in that taxable year, and.
Puerto Rico is an unincorporated territory of the United States and Puerto Ricans are U.S. citizens; however, Puerto Rico is not a U.S. state, but a U.S. insular area. Consequently, while all Puerto Rico residents pay federal taxes, many residents are not required to pay federal income taxes.
You have to pay regular US capital gain tax on the rest. If you stay in Puerto Rico for 19 years (and Act 60 sticks around), you'll get the 0% rate on 50% of your gain.
Specifically, a U.S. citizen who becomes a bona fide Puerto Rico resident and moves his or her business to Puerto Rico (thus, generating Puerto Rico sourced income) may benefit from a 4% corporate tax/fixed income tax rate, a 100% exemption on property taxes, and a 100% exemption on dividends from export services.
Act 22 of 2012 ?also known as the Act to Promote the Relocation of Investors to Puerto Rico (Spanish: Ley para Incentivar el Traslado de Inversionistas a Puerto Rico)? is an act enacted by the 16th Legislative Assembly of Puerto Rico that exempts local taxes on certain passive income generated by individuals that ...
Along with Puerto Rico Tax Act 20, Puerto Rico adopted an additional incentive, the ?Act to Promote the Relocation of Individual Investors,? Puerto Rico Tax Act 22, to stimulate economic development by offering nonresident individuals 100% tax exemptions on all interest, all dividends, and all long-term capital gains.