Industry · 06
Relocation & Residency
A move can reshape a tax position more than any return — when the residency is real.
Relocation is one of the few decisions that can materially change a client's lifetime tax position. Moore & Farrington advises individuals and business owners considering a move — to Puerto Rico under Act 60, or between U.S. states — on the planning, documentation, and compliance that protect the result.
For clients pursuing Puerto Rico residency under Act 60, we help establish and substantiate bona fide residency: the presence test, the closer-connection test, the source-of-income rules, and the annual filings that maintain the individual resident decree. We coordinate the federal side — the U.S. residency that continues to apply to non-Puerto Rico source income — alongside the Puerto Rico position, so nothing is left to assumption. For business owners relocating operations, we advise on the 4% business tax rate and the export-services rules that make the move worthwhile.
For clients moving between states — often out of California or another high-tax state into a no-income-tax state — the work is residency and domicile. We help you establish domicile cleanly, document the closer connection, manage the 183-day and statutory-residency tests, and prepare for the residency examination that high-tax states increasingly pursue. Sourcing matters too: where income is earned, where it is received, and how a mid-year move splits the year.
Relocation tax planning is legitimate, powerful, and unforgiving of shortcuts. The benefit is real only when the residency is real, the documentation is complete, and the filings are consistent. We bring the same steady standard to a move that we bring to every return.
Where we focus
- Puerto Rico Act 60 residency
- State domicile & statutory residency
- 183-day tracking & residency defense
- Move timing & income sourcing
- Business relocation & nexus