Digital Nomad

Digital Nomad in Puerto Rico: Leveraging Act 60 and U.S. Tax Rules

Act 60 offers substantial tax incentives for individuals relocating to Puerto Rico — but understanding U.S. territory tax rules is key to maximizing benefits.

By NomadicTax Research Team • 5-8 min read • August 23, 2026

## What Is Puerto Rico Act 60? Formerly Acts 20 and 22, **Act 60, the Incentives Code of Puerto Rico**, was designed to attract investors, service businesses, and high-net-worth individuals. Key benefits include: - **100% tax exemption on dividends**, interest, and capital gains from Puerto Rico-source investments (for certain resident individuals). - Reduced income tax rates for eligible service-based businesses. - A full exemption for passive income, subject to eligibility and application requirements. ## Interaction with U.S. Federal Tax for U.S. Citizens or Green Card Holders Even as Act 60 provides local tax relief, U.S. citizens or permanent residents must still obey federal rules: - Bona fide residence tests under IRC § 937 matter: only certain Puerto Rico-source income may be excluded from the U.S. federal return.([irs.gov](https://www.irs.gov/publications/p570?utm_source=openai)) - Passive U.S.-source income (e.g. dividends from U.S. stocks) remains subject to U.S. federal tax. - Filing requirements: must file both Puerto Rico return (worldwide income if bona fide resident) and U.S. Form 1040 (excluding PR-source income if eligible). - Must file **Form 8898** if becoming bona fide resident and worldwide income exceeds US$75,000.([irs.gov](https://www.irs.gov/instructions/i8898?utm_source=openai)) ## How to Become Eligible Under Act 60 - Move to Puerto Rico and satisfy bona fide residence (183 days, tax home, closer connection). - Apply for **residential decree** with Puerto Rico authorities under Act 60. - Maintain physical presence — often at least 183 days a year. - Ensure business or investment income qualifies under rules (some sectors excluded). ## Example: Remote Worker & Capital Gains Luis, a remote software engineer and U.S. citizen, moves to Ponce, Puerto Rico, in 2025. He applies and gets approved under Act 60. - He earns US$100,000 from U.S. clients (service income) and US$30,000 from capital gains on Puerto Rico-source real estate investments. - Under Act 60: - Puerto Rico taxes service-income under reduced rates; Puerto Rico-source capital gains may be exempt. - U.S. federal return excludes the Puerto Rico-source capital gains and some interest/dividends from PR investments if bona fide resident. - His U.S. client income (U.S. source) still taxed federally, though he may have PR credit for U.S. taxes paid. ## Pitfalls & Monitoring - IRS scrutiny: ensure eligibility, declarations, and documentation robust. - Temporary residence: spending too many days outside PR may break bona fide status. - Business source of income: ensure business is structured to provide “services from Puerto Rico” rather than merely delivered there. - Stay updated: tax relief deadlines effect, e.g. disaster relief for territories that might affect Puerto Rico or nearby islands. ## Final Notes Act 60 offers foundational tax incentives, but U.S. federal jurisdiction remains impactful. Strategic planning, clear documentation, and strong structure ensure you benefit fully while staying compliant.