Puerto Rico Act 60: The Only Way for Americans to Pay 0% Capital Gains

Tax Tips / Geo-Arbitrage

Puerto Rico Act 60: The Only Way for Americans to Pay 0% Capital Gains

By Team BMT Jan 16, 2026

💡 Executive Summary

  • Problem: US Citizens are taxed on worldwide income, regardless of where they live. Moving to Dubai or Singapore doesn’t stop the IRS (unless you renounce citizenship).
  • Solution: Become a Bona Fide Resident of Puerto Rico under Act 60 (formerly Act 20/22).
  • Result: Pay 0% Capital Gains Tax on assets acquired/appreciated after the move, and 4% Corporate Tax on exported services.
⚠️ YOU MUST ACTUALLY MOVE
This is not a “PO Box” strategy. The IRS tracks your location (cell phone, credit cards). You must spend at least 183 days/year in Puerto Rico and have your “Center of Vital Interests” (family, doctor, gym) on the island.

For Crypto Whales, Hedge Fund Managers, and Digital Entrepreneurs (Tier L3+), Puerto Rico is the ultimate “Escape Hatch.” Thanks to IRC § 933, income sourced within Puerto Rico is exempt from US Federal Tax. It is the only place on earth where a US passport holder can legally ignore the IRS for capital gains.

🧐 Core Mechanic: The “Split” Basis
Gains accrued before you move are still taxable in the US (Built-in Gain). Only the gains accrued after you become a resident are 0%.
*Tip: Use the 10-year rule to eventually wipe out pre-move gains (wait 10 years to sell).

Performance Simulation

Exit Event ($10M Capital Gain)
California Resident ~37% Combined Tax
$6.3M Net
Puerto Rico Resident (Act 60) 0% Tax (After Move)
$10.0M Net

Tax Comparison: US vs. PR

Tax Type Mainland US (Fed + State) Puerto Rico (Act 60)
Capital Gains 23.8% + State (up to 13.3%) 0%
Corporate Tax 21% + State 4% (Export Services)
Dividends 23.8% + State 0% (From PR Corp)
“It’s not just about saving tax; it’s about freedom. Puerto Rico offers the benefits of an offshore tax haven with the protection of the US legal system and currency.”
BMT designs for tax reality, not theory.