Discussion about this post

User's avatar
Alex Kirby's avatar

This is awesome, Brain. Answered a lot of questions I had. Didn't know about the rules about staying international to lower the amount of days from 183, but that's a plus.

Expand full comment
JF's avatar

Thanks for the overview. Heads up, there are all sorts of interesting things you can do with a Puerto Rican corporation and a bona fide PR residency. You can be excluded from the nasty controlled foreign corporation (CFC) rules and Subpart F reporting that regular (non-Puerto Rican) US citizens have to do with their foreign corporations, which force "distributions" and thus force taxation each year instead of tax-free compounding offshore before profit repatriation.

I found the following article helpful in explaining how you might structure a PR corporation with European pass-through LLCs (disregarded entities) holding the corporation's intellectual property to minimize tax, something that wouldn't be possible if you weren't a PR resident with a PR corp:

https://www.floridabar.org/the-florida-bar-journal/u-s-international-tax-planning-for-bona-fide-residents-of-puerto-rico/

Expand full comment
29 more comments...

No posts