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PALMAS

                                                                                                                                                   DEL MAR
              THE INDIVIDUAL INVESTORS ACT

              OFFERING ATTRACTIVE TAX INCENTIVES FOR INDIVIDUALS RELOCATING TO PUERTO RICO





              The Individual Investors Act (Act 22) seeks to      • All capital gains accrued and unrealized prior to   REQUIREMENT FOR NEW RESIDENTS
              attract new residents to Puerto Rico by providing     becoming a new resident will be subject to a tax:  THAT HAVE NOT LIVED IN PUERTO
              a total exemption from Puerto Rico income taxes       (i) at the prevailing tax rate (currently 10%), if   RICO FOR THE LAST 15 YEARS:
              on all passive income realized or accrued after       such gain is recognized within 10 years of new    • Physical presence in Puerto Rico for a period of 183
              such individuals become bona fide residents of        residence in Puerto Rico, and                     days during the taxable year will create a presump-
              Puerto Rico.
                                                                    (ii) 5%, if such gain is recognized after said    tion of residence in Puerto Rico for tax purposes
                                                                    10-year period. Such taxes paid may be used as    • Section 937 of the U.S. Internal Revenue Service
              TAX TREATMENT                                         a credit in another jurisdiction that taxes such   Code provides additional guidance as to what is
              Tax exemptions conferred under Act 22 are valid       gains. The U.S. will not tax any prior unrealized   generally considered a bona fide resident: (a) no
              through December 31, 2035:                            gains if recognized after 10 years of residence    tax home outside Puerto Rico during the tax year,
                                                                    in Puerto Rico                                    and (b) no closer connection to the U.S. or a
              Passive Income Exemptions:                                                                              foreign country.

              • New residents will enjoy a 100% tax exemption
                from Puerto Rico income taxes on all dividend and
                interest income

              • Interest and dividends that qualify as Puerto
                Rico source income will not be subject to federal
                income taxation under Section 933 of the IRS Tax
                Code.
              • New resident investors may be able to reduce the
                tax rate applied on interest and dividend income
                coming from sources outside of Puerto Rico
                (including the source country taxation) to 0% or
                10%, respectively, by investing through certain
                Puerto Rico investment vehicles

              Capital Gain Exemptions:

              • All capital gains accrued after becoming a
                new resident will be 100% exempt from Puerto
                Rico taxes. These gains will not be subject to
                federal taxes.











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