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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 DateApril 26, 2021
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

  • Identify 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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Culhanemeadows

Patrick is a partner with Culhane Meadows, a national law firm with a prominent international area practice. Patrick practices exclusively in the area of international taxation. He has extensive experience handling complex tax planning, structuring, and compliance issues for foreign businesses with United States operations, United States businesses with foreign operations, and individual taxpayers with international ties. Patrick regularly works with advisors both in the United States and abroad to assist with their clients’ international tax issues.

Patrick is a prolific contributor to many international tax journals, including Tax Notes and the Journal Of International Taxation. He is an active speaker and panelist for national seminars and webinars, including regularly scheduled presentations with CPAacademy.org on various international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and an LL.M. from New York University School of Law.  His bar admissions include Pennsylvania, Florida, New Jersey, and Georgia.

Each year from 2016-2019, Patrick has been recognized by Super Lawyers as a Rising Star. Finance Monthly, a United Kingdom-based publication named Patrick Estate Planning Lawyer of the Year (United States) for 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.

 

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