A framework for coordinating investments, liquidity, tax reporting, business interests, estate planning, and the advisor team
Executive Summary
A decree is not a financial plan.
Moving to Puerto Rico under Act 60 can create meaningful opportunities, but the decree addresses only one part of a family’s financial life. Successful owners and investors often arrive with businesses, legacy investments, private funds, real estate, trusts, insurance, lending relationships, and advisors in multiple jurisdictions.
The result is usually not a lack of expertise. It is a lack of coordination. A tax attorney may handle the decree, a CPA may prepare the returns, an investment advisor may manage the portfolio, and an estate attorney may update documents – yet no one may be accountable for how the decisions interact.
The Bespoke Act 60 Financial Architecture
The architecture organizes the work into six tangible client deliverables:
- 1Act 60 Financial Map – A single view of the balance sheet, cash flow, entities, business interests, family goals, and major decisions.
- 2Pre-Move / Post-Move Asset Ledger – A durable record of acquisition dates, basis, move-date values, ownership, and supporting documents.
- 3Income Source & Character Matrix – A common language for capital gain, interest, dividends, ordinary income, and mixed K-1 items.
- 4Portfolio Architecture – An allocation built around the job each dollar must perform, not a generic mainland model.
- 5Specialist Team Map – Clear roles for tax, legal, estate, business, investment, insurance, banking, and real estate professionals.
- 6Annual Family Office Calendar – A recurring cadence for documentation, filings, reviews, implementation, and family coordination.
Act 38-2026 amended future-applicant rules and extended the program through 2055. Start with the client’s decree, application date, residency facts, and current law. [1][2]
THE COORDINATION GAP: THE RISK
The move can simplify one part of the tax picture and complicate everything else.
Act 60 may create meaningful tax opportunities for qualifying decree holders, but benefits are not automatic or uniform. Outcomes depend on the client’s decree, application date, bona fide residency, income source and character, acquisition dates, entity structure, reporting, current law, and other facts. Investors should weigh potential tax benefits against recordkeeping and compliance burdens, fees, concentration, credit, liquidity, valuation, reporting complexity, and possible loss of principal. Qualified Puerto Rico and U.S. tax and legal professionals should evaluate individual circumstances. [1][4][5][6][7]
THE BESPOKE ACT 60 FINANCIAL ARCHITECTURE
Six deliverables turn a tax opportunity into an operating system.
Each deliverable answers a different question, creates a shared record, and gives the family and advisor team a common way to make decisions.
FINANCIAL MAP + ASSET LEDGER
Start with the whole balance sheet, then preserve the timeline.
The architecture begins by documenting what exists today and separating facts that may matter later. A family should not have to rebuild its financial history in the middle of a sale, audit, estate event, or portfolio transition.
A PRACTICAL CHECKLIST BEFORE YOU COMMIT CAPITAL
A good deal should be able to survive thoughtful review.
PORTFOLIO ARCHITECTURE
Build the portfolio around jobs, not product categories.
Act 60 can change the after-tax tradeoffs, but it does not change the family’s need for growth, liquidity, diversification, discipline, and downside awareness. The portfolio should remain understandable even when the underlying strategies are sophisticated.
TEAM MAP + ANNUAL CALENDAR
The plan works only when roles and timing are clear.
Act 60 families often have excellent specialists. The architecture makes their work more valuable by clarifying ownership, communication, sequencing, and the recurring calendar.
5 | THE SPECIALIST TEAM MAP
6 | THE ANNUAL FAMILY OFFICE CALENDAR
A DISCIPLINED PROCESS
Tailored planning does not mean improvised planning.
Every family has a different business, decree, balance sheet, advisor team, and definition of a life well lived. The recommendations should be custom-tailored, but the process should remain disciplined so important decisions are not missed.
THE FIRST 100 DAYS
THE ACT 60 FINANCIAL ARCHITECTURE ASSESSMENT
Before assuming the plan is coordinated.
Mark each statement Yes, No, or Not Yet. The objective is not to produce a score. It is to identify where better documentation, specialist review, or coordination could help the family.
A PERSONAL PERSPECTIVE
The Act 60 specialization is an extension of our business-owner work, not a departure from it.
At Bespoke Capital, our practice remains built around one client type: successful privately held business owners. We help owners become financially independent of their businesses, prepare for liquidity, coordinate specialists, and steward the wealth after the transaction.
Act 60 families are rarely looking for only an investment portfolio. They are coordinating a business, liquidity, residency, taxes, estate planning, private deals, real estate, and a new chapter of family life.
My role is not to replace the CPA, attorney, banker, investment professional, or other specialist. It is to make sure the right people are at the table, the right questions are assigned, decisions are sequenced correctly, and the plan actually gets implemented.
Why work with specialists
The strongest fit is a founder, active business owner, post-exit entrepreneur, or family office whose financial picture has become too complex for disconnected advice. The goal is not to make the plan more complicated. It is to make the complexity understandable, intentional, and coordinated.
If you are a business owner or Act 60 family beginning to organize the whole picture, we invite you to schedule a confidential conversation.
Contact us at cody@bespokecap.com to begin the discussion.
Important Disclosures
This whitepaper is provided for educational and informational purposes only and does not constitute tax, legal, investment, financial, business, estate-planning, accounting, residency, valuation, transaction, or other professional advice. It is not an offer, solicitation, or recommendation to buy or sell any security, business interest, entity, structured investment, private fund, or other asset.
Act 60 benefits are not automatic and are not uniform. Outcomes depend on the client’s decree, application date, bona fide residency, income source and character, acquisition dates, entity structure, reporting, current law, and other individual facts. No representation is made that any tax rate, exclusion, sourcing result, investment outcome, or planning strategy will apply or be achieved.
Tax laws, sourcing rules, residency standards, estate-planning techniques, investment structures, and market conditions are complex and subject to change. Strategies should be reviewed and implemented only with the client’s qualified Puerto Rico and U.S. tax and legal professionals. Raymond James and its financial advisors do not provide tax or legal advice.
Investments involve risk, including possible loss of principal. Structured investments, hedge funds, private equity, direct deals, real estate, derivatives, and other alternative investments may be speculative, illiquid, complex, leveraged, difficult to value, and unsuitable for some investors. Past performance does not guarantee future results.
Bespoke Capital is not a registered broker/dealer and is independent of Raymond James Financial Services. Securities offered through Raymond James Financial Services, Inc. Member FINRA/SIPC. Investment advisory services offered through Raymond James Financial Services Advisors, Inc.
This content was created with the assistance of artificial intelligence (AI) and reviewed for quality and relevance. AI-assisted content may not reflect all current developments or nuanced human perspectives.
© 2026 Bespoke Capital. All rights reserved.
Registered branch office: 6 Concourse Parkway, Suite 2175, Atlanta, GA 30328 | 770.325.6957
The information contained in this material does not purport to be a complete description of the securities, markets, or developments referred to in this material. The information has been obtained from sources considered to be reliable, but we do not guarantee that the foregoing material is accurate or complete. Any opinions are those of Bespoke Capital and not necessarily those of Raymond James.
Changes in tax laws or regulations may occur at any time and could substantially impact your situation. While we are familiar with the tax provisions of the issues presented herein, as Financial Advisors we are not qualified to render advice on tax or legal matters. Raymond James and its advisors do not offer tax or legal advice. You should discuss any tax or legal matters with the appropriate professional.
Selected Primary Sources
1. Puerto Rico Act 60-2019, as amended
Puerto Rico Incentives Code.
2. Puerto Rico Act 38-2026
Amendments affecting future Individual Resident Investor applicants and extending the program through 2055.
3. Internal Revenue Code Section 933
Exclusion of qualifying Puerto Rico-source income for bona fide residents.
4. Internal Revenue Code Section 937
Bona fide residency, source rules, and reporting framework.
5. Treasury Regulation Section 1.937-1
Presence, tax home, closer connection, year-of-move rules, and reporting.
6. Treasury Regulation Section 1.937-2
Possession source rules, marketable securities, nonmarketable property, dividends, interest, and other items.
7. IRS Publication 570 (2025)
Tax Guide for Individuals With Income From U.S. Territories.
8. IRS Form 8898 and instructions
Notice when an individual begins or ends bona fide residence in a U.S. territory.
9. IRS LB&I Active Campaign – Puerto Rico Act 22
Compliance focus on Section 937 residency and the classification of U.S.-source versus Puerto Rico-source income.
The sources above are a starting point, not a substitute for professional advice or current legal research.
