Founded by veteran Wall Street attorney, Filippo Cinotti, Esq., Cinotti International LLC is a Puerto Rico based boutique legal and tax consulting firm located in the La Milla de Oro (i.e., the Golden Mile) of Puerto Rico’s financial district providing cross border M&As, real estate, general corporate and international tax services to a distinguished roster of clients primarily located in the Mainland United States and Western Europe.”
Clients of the Firm include governmental entities, investment funds, family offices, banks, technology businesses, fashion companies, food and industrial machinery manufacturers and distributors, as well as individual investors.
The Commonwealth of Puerto Rico holds a unique position as self-governing U.S. territory of the United States. Pursuant to §933 of the Internal Revenue Code (IRC), Puerto Rico source income is excluded from U.S. federal income tax. In its quest to attract foreign investment, local legislation known as Act 60, or the Puerto Rico Incentives Code, was enacted in 2019, providing among other things a 4% flat corporate income tax rate on a wide variety of so called eligible services exported from Puerto Rico by qualifying businesses and a 0% individual tax rate on distribution of dividends at the shareholder level made to bona fide residents of Puerto Rico (these corporate level tax incentives were formerly known as Act 20 incentives). In addition, pursuant to legislation previously known as Act 22 incentives, individual investors who are bona fide residents of Puerto Rico may become eligible for a 100% income tax exemption on Puerto Rico source short term and long-term capital gains and other types of Puerto Rico source passive income, such as dividends. A substantial portion of our Firm’s practice focuses on designing cross-border, U.S. tax compliant and efficient structures and strategies for individuals and businesses in various industries seeking to relocate to Puerto Rico.
Further information on Cinotti International LLC’s practice areas and on its professionals’ individual biographies is available upon request.
