Puerto Rico Amended Equity Fund Partnership Agreement

State:
Multi-State
Control #:
US-PE-D1AM
Format:
Word; 
Rich Text
Instant download

Description

This is a sample private equity company form, an Equity Fund Partnership Agreement. Available in Word format.
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FAQ

The first requirement has to do with time spent in Puerto Rico. Individuals are expected to spend 183 days a year in the territory. Further, they must spend at least 549 days in a three-year period. Also, they are not permitted to be present in the US for more than 90 days in any year.

Overview of Puerto Rico Act 20 Tax Incentives Puerto Rico operates as a Foreign Tax Structure, where federal income taxes do not apply. It works under a Controlled Foreign Corporation (CFCs) tax treatment; in which federal income taxes defer until repatriation of profits occurs.

Along with Puerto Rico Tax Act 20, Puerto Rico adopted an additional incentive, the ?Act to Promote the Relocation of Individual Investors,? Puerto Rico Tax Act 22, to stimulate economic development by offering nonresident individuals 100% tax exemptions on all interest, all dividends, and all long-term capital gains.

Puerto Rico Act 22 ? The Individual Investors Act As long as an individual is a bona fide resident and their source of income is in Puerto Rico, they will not have to pay the federal income tax rate which ranges from 10% to as high as 37%.

Changes to Act 20 Act 20 now has an employee requirement where exempt businesses generating an annual revenue of at least $3,000,000 must directly employ a minimum of one full-time employee who is a Puerto Rican resident. There has also been a reduction in property and municipal taxes.

Act 52-2022?enacted into law in Puerto Rico on June 30, 2022?allows taxpayers to amend their existing tax decrees to replace the existing income tax and royalty withholding tax framework with a new income tax and royalty withholding tax framework.

The Act allows for domestic or foreign investment vehicles structured as partnerships or limited liability companies to elect to be treated as a fund under the Act (?Fund?) and to obtain Puerto Rico tax benefits to Fund investors, among others, under the Puerto Rico Internal Revenue Code of 2011, as amended, (the ?Code ...

And as a resident, you're eligible for the Act 22 exemption and you will escape the GILTI taxation by the IRS for your Act 20 company. To satisfy the first test, you must meet any one of the following five conditions: 1) Be present in Puerto Rico for at least 183 days during the tax year.

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Puerto Rico Amended Equity Fund Partnership Agreement