Estate Tax Rules for Puerto Rico Residents

Offshore Tax with HTJ.tax · Apr 30, 2026 · 1m

Puerto Rico occupies a unique position in the U.S. tax system—and that uniqueness extends to estate tax treatment.⚖️ 1️⃣ A Hybrid RegimeUnder the Internal Revenue Code:• Individuals domiciled in Puerto Rico may, in certain cases, be treated similarly to:👉 Nonresident aliens (NRAs) for U.S. estate tax purposes🌍 2️⃣ What Does This Mean in Practice?Instead of worldwide taxation:• Only U.S.-situs assets are subject to U.S. estate tax📊 Examples of U.S.-Situs Assets• U.S. real estate • Shares of U.S. corporations • Certain U.S.-based investments👉 Non-U.S. (including Puerto Rico) assets are…