Comprehensive Act 60 Compliance Review for Physicians

The cornerstone of benefiting from Act 60 as a physician is the proper sourcing of your professional service income. To qualify for the 4% corporate tax rate, income must be derived from services performed in Puerto Rico for clients outside of Puerto Rico. For doctors, this creates unique opportunities and complexities, particularly with the rise of telemedicine. Our review meticulously examines your patient base, service agreements, and billing locations to validate that your income is correctly sourced. We analyze patient location data, telemedicine platform architecture, and inter-company service agreements to identify potential mischaracterizations that could jeopardize your decree. As noted in the GAO Report GAO-26-107225, proper income sourcing is a primary focus of IRS scrutiny, making it an area where precision is paramount. We help ensure your operations align with the stringent requirements of both the IRC and Puerto Rico's Incentives Code.

How you structure your medical practice is critical. Establishing a Puerto Rican Export Services entity is the first step, but optimizing the flow of funds and corporate governance is an ongoing challenge. We analyze your corporate structure, including the relationship between your US-based practice (if any) and your new Puerto Rican entity. This includes a review of transfer pricing agreements to ensure they are at arm's length, a key requirement to avoid challenges from the IRS. Furthermore, our analysis covers the treatment of dividend income from your Puerto Rican corporation, which is 100% tax-exempt to you as a bona fide resident. Traditional CPA firms often charge between $5,000 and $25,000 for this level of structural review, yet our AI-powered platform provides this analysis with greater speed and cost-effectiveness, all verified by certified public accountants.

Telemedicine presents a significant opportunity for physicians under Act 60, but it also introduces new compliance risks. The location of the service is key. Are you treating patients in the US from your office in San Juan? The income is likely PR-sourced. But what if the patient is also traveling? What if you consult with other doctors in the US? These nuances determine whether your income qualifies. Our system is designed to catch these subtle but critical distinctions. We review your telemedicine service protocols, patient intake processes, and digital infrastructure to provide a clear picture of your compliance risk. With the adoption of AI-powered compliance tools growing by over 80%, leveraging technology for this analysis is no longer a luxury—it's a necessity for any physician serious about maintaining their decree in good standing.