Puerto Rico Act 60 remains the cleanest legal route for US citizens to achieve a 0% capital-gains tax rate on post-residency crypto appreciation. The framework is well-paved, well-litigated, and used by hundreds of crypto-native principals — but the 2026 reality has tightened.
What Act 60 actually offers
- 0% capital gains on post-residency appreciation of personally held assets, including crypto.
- 4% corporate tax rate on qualifying export-services businesses.
- Required: become a bona-fide PR resident (183+ days/year, primary home, tax home, closer-connection test).
What changed for 2026
The IRS has stepped up scrutiny. New requirements include a $10,000 annual donation to a registered PR nonprofit, more detailed substance documentation, and stricter evidence of physical presence. The benefit is still real — but cosplay residency no longer flies.
The crypto-specific catch
Act 60’s 0% rate applies only to appreciation that accrues after you become a bona-fide resident. If you held BTC at $30K and moved to PR when it was $90K, the first $60K of appreciation is still taxed at federal rates. Only the post-move appreciation is exempt.
Who it actually fits
- You already plan to relocate, full life-stop.
- Your crypto position is large enough that the 0% on post-move gains justifies the relocation.
- You have a PR-licensed counsel walking you through the substance requirements.
ARCrypto coordinates with PR counsel for members considering the move. Book a private call.