News & Events

Puerto Rico Act 60 allows qualifying individuals and businesses to avoid federal income tax for both ordinary income and capital gains. However, while this was precisely the purpose for which the Act (and its predecessors—Puerto Rico Acts 20 and 22) was established, the Internal Revenue Service (IRS) is now cracking down on U.S. taxpayers who use the Act to avoid federal tax liability. Crucially, the IRS is pursuing criminal inquiries in some cases, and these IRS criminal tax audits present risks for both substantial fines and prison time.

The United States Supreme Court has recently ruled in favor of taxpayers in a significant case involving Foreign Bank Account Reporting (FBAR) requirements. The ruling addresses the penalty structure for non-willful violations of FBAR reporting obligations, emphasizing a per-report basis. This decision carries substantial implications for taxpayers and underscores the critical need for individuals facing FBAR-related challenges to secure the services of an experienced Washington DC tax attorney.