One hedge-fund manager, Pascal Forest, has taken the additional step of setting up his firm, Forest Investments LLC, in San Juan. Forest, a former portfolio manager at London-based BlueGold Capital Management LLP, said the tax incentives played into his decision to move to the island, as did his wife, who is Puerto Rican and wanted to come home after 16 years.
In order to become eligible for the new tax breaks, a person must live on the island for at least 183 days a year and prove that a preponderance of his social and family connections are there. Any person who moves to the island signs a contract with the government that guarantees the tax break through Dec. 31, 2035.
“You have to actually become a bona fide resident of Puerto Rico, bring your children,” said Fernando Goyco-Covas, a tax lawyer at Adsuar Muniz Goyco Seda & Perez-Ochoa PSC. “You cannot do this just claiming you are a resident.”
Puerto Rico occupies a space between foreign and domestic status with U.S. citizenship for residents, its own Olympic team and a tax system that allows individuals and companies the chance to elude the IRS.
The U.S. territory’s leaders are seeking to lure mainland residents such as hedge-fund billionaire John Paulson. Moving to Puerto Rico could allow Paulson and other top-earning taxpayers to shield future income from the Internal Revenue Service without giving up their passports.
Puerto Rico, eager for economic growth, is making an unusually direct pitch to wealthy Americans that risks a political backlash from Congress, said John Buckley, a former tax counsel for Democrats on the House Ways and Means Committee.
The catch is that you can't just set up a post office box and call yourself a resident. You have to move for real. Like Damon Vickers has.
The zero percent tax on investment income, and the 4 percent corporate tax, went into effect at the start of 2012. The goal is for 500 wealthy investors to come in the next four years. So far, 77 have applied.
The investment tax breaks are guaranteed until 2036. Only congressional action — or granting Puerto Rico statehood — would put a stop to them. But while some say this is just Puerto Rico becoming the latest tax haven, there has been little serious opposition.