Mastering Fund Structuring Under Act 60
Carried Interest: A Detailed Tax Analysis
Sourcing Management & Performance Fees Correctly
Frequently Asked Questions
How does Act 60 affect my existing fund structure?
Relocating under Act 60 often requires restructuring to segregate Puerto Rico-sourced income and ensure it qualifies for the tax incentives. Our review can help identify the specific modifications your structure may need, from creating new entities to drafting compliant intercompany agreements.
What are the biggest mistakes hedge fund managers make with Act 60?
Common errors include improper sourcing of management fees, misunderstanding the rules for carried interest, and failing to meet the bona fide residency requirements. Our comprehensive review is designed to catch these and over 200 other potential compliance issues.
Is my carried interest really 0% tax under Act 60?
Achieving a 0% tax rate on carried interest is possible but depends on strict adherence to sourcing rules and the timing of your residency. Our analysis can help determine if your specific situation qualifies and identify potential risks.
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This content is for informational purposes only and does not constitute tax, legal, or accounting advice.
