Puerto Rico Tax Home for US Citizen Living In Europe

[crassus54]

Dear OCT,

It is a pleasure to get involved in this forum for the first time, since setting up my account.

Firstly, I would like to outline my situation:
- I am a semi-retired investor, who has US and Italian citizenship, with close cultural and personal ties to France and the US.
- Tax Home and Residence in Nevada. All my personal and economic connections are here, as well as some properties, bank accounts, investments, and other interests.
-Due to the "Center of Vital Interests Determines Tax Residency" clause in the US-French tax treaty, I have been living in France for years, generally less than 6 months per year, without switching tax residency to France (My nightmare).
- I am planning to move my Tax Home/Residency to Puerto Rico, although it is not my plan to spend any more than a month per year there. My plan was originally to continue but only file taxes in Puerto Rico, although my issue is that Puerto Rico requires no other tax residency to gain bona fide residency status, and France and most countries in Europe do not have a tax treaty with Puerto Rico.

So in this configuration, how could I in theory live a life in Western Europe without having to pay taxes outside my Puerto Rico residency set-up?

I am discussing this with various professionals, but would love to get a weigh-in. Let me know if there are any more details that I can add to this.

Best Regards,

J

 

[TheCryptoAnt]

wait the USA tax treaty dont apply to PR?

 

[Martin Everson]

Seek professional tax advise when it comes to anything US.

Puerto Rico - Individual - Foreign tax relief and tax treaties

Detailed description of foreign tax relief and tax treaties impacting individuals in Puerto Rico

taxsummaries.pwc.com

 

[crassus54]

wait the USA tax treaty dont apply to PR?

That is correct, if you read the first few lines, US is defined excluding territories.

Seek professional tax advise when it comes to anything US.

Puerto Rico - Individual - Foreign tax relief and tax treaties

Detailed description of foreign tax relief and tax treaties impacting individuals in Puerto Rico

taxsummaries.pwc.com

That is generally a good idea, but I am attempting to get a better idea of what I want/can get with my current situation before drafting everything up legally.

 

[jafo]

That is correct, if you read the first few lines, US is defined excluding territories.


That is generally a good idea, but I am attempting to get a better idea of what I want/can get with my current situation before drafting everything up legally.

If I were you, I would find a CPA/JD in Puerto Rico and work it out. US tax issues are complicated as H*ll and if you get a CPA/JD in Puerto Rico, pay him a retainer, and get your Letter of Opinion...even if he/they get(s) it wrong, there would be no mens rea on your part.