HH LAW offers invaluable guidance to clients aiming to become bona fide residents of Puerto Rico under IRC Section 937. Our proficiency in navigating the complexities of Puerto Rico's tax system allows individuals and businesses to benefit from significant tax incentives, such as Act 20 and Act 22, which offer reduced tax rates on income and gains for new residents and businesses. This strategic approach to leveraging Puerto Rico's favorable tax laws underscores our firm's commitment to maximizing our clients' financial outcomes.

For non-U.S. clients looking to invest within the United States, our firm provides a full range of services designed to optimize tax efficiency and ensure compliance:● Foreign Bank Account Reports (FBARs): Guidance on reporting foreign bank and financial accounts.● Offshore Voluntary Disclosure Program: Support for disclosing unreported offshore assets and income.● Structuring Inbound Foreign Investments: Customized investment structures to minimize tax liabilities.● Foreign Investment in U.S. Real Property (FIRPTA): Assistance with real estate transactions to ensure FIRPTA compliance, focusing on entity structuring to prevent estate tax inclusion.

Our services extend to U.S. persons and businesses investing abroad, offering:● Structuring Outbound U.S. Businesses: Efficient structures for operating internationally.● Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standards (CRS): Ensuring compliance with international reporting requirements.

We provide specialized estate and gift tax planning for NRAs, including the use of Qualified Domestic Trusts (QDOTs) to enable non-U.S. citizen spouses to qualify for the marital deduction, preserving assets within the U.S. while complying with federal estate tax laws.