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Act 60, Section 933, and the Tax Benefits of Puerto Rico

ACT 60, SECTION 933, AND THE TAX BENEFITS OF PUERTO RICO

Cost Free
Presentation Length 1.5 hours

Recorded DateFebruary 8, 2024
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

United States-based taxpayers are taxed on worldwide income, irrespective of source. While United States tax residents can be reclassified as nonresidents for tax liability purposes, no options exist for reclassifying United States citizens short of expatriation (which in itself carries American tax repercussions). However, section 933(2) offers appealing options for some: an exemption from (United States) tax for Puerto Rican-sourced income earned by Puerto Rico residents. Companies can also relocate to Puerto Rico to significantly alter American tax liabilities.

Learning Objectives:


  • Identify default tax rules applicable to United States taxpayers/reclassification options

  • Determine American tax rules for Puerto Rican resident individuals and businesses

  • Recognize sourcing rules applicable for assorted income types earned by Puerto Rican residents

  • List examples of the application of American anti-deferral rules to Puerto Rican corporations

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Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.

Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.

Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.

Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.
 

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