IRS Enforcement in Puerto Rico Triggers Incipient Tax Court Battles

An aerial perspective of a sandbar or tidal inlet, where turquoise ocean water flows between two sandy landmasses, offering a stunning contrast with the golden sand.An aerial perspective of a sandbar or tidal inlet, where turquoise ocean water flows between two sandy landmasses, offering a stunning contrast with the golden sand.

IRS Enforcement in Puerto Rico Triggers Incipient Tax Court Battles

June 15, 2026

TAX NOTES FEDERAL

This article by Partner Hale Sheppard offers an overview of the tax advantages of relocating to and/or operating a business from Puerto Rico, examines noteworthy enforcement actions thus far, and explores four recent events demonstrating that IRS efforts are generating results, including the start of what surely will be many Tax Court disputes.

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Hale E. Sheppard

Partner

Atlanta, United States

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