
Sen. Ron Wyden, the committee's ranking Democrat, said that ultra-wealthy investors may have improperly shifted billions of dollars in income to Puerto Rico through questionable legal opinions provided by major law firms. The concern is not that Americans legally moved to Puerto Rico to reduce future taxes, but that some allegedly tried to erase taxes they already owed before becoming bona fide residents.
"The IRS is appropriately seeking to determine whether individuals who have relocated to Puerto Rico are misusing Puerto Rico Act 60 to shelter billions of dollars in income from U.S. taxes," Wyden wrote in a letter to Jarod Koopman, the IRS chief tax compliance officer. "My understanding is that there are dozens of ultra-wealthy investors who received dubious advice from partners at major law firms."