House and Senate New Tax Bill
For individuals who become bona-fide residents (BFR) of PR, there is nothing in the language of the new amendments that would impact their Act 22 tax advantages. The minimum global tax does not apply to BFR of a possession - these individuals are outside of the US tax system as long as their income is from PR sources (i.s. capital gains from trading securities and commodities while BFR in PR). The entities under Act 20 are purely PR-entities, which are also outside of the US Fed taxation and for these Act 20 will stay the same. If a BFR of PR owns an Act 20 company and is an Act 22 decree-holder, such person will still receive dividends from the Act 20 company in PR under his/her Act 22 tax free and his/her Act 20 entity will be charged the reduced tax.