Question: Would it be tax compliant to say income is sourced in Puerto Rico if a PR co wholly owned a NV LLC (no employees) and all revenues flowed thru to PR?

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Would it be tax compliant to say income is sourced in Puerto Rico if a PR co wholly owned a NV LLC (no employees) and all revenues flowed thru to PR?

The Nevada company’s only purpose is used to get merchant processing since banks won’t underwrite a PR company. All owners live and operations are done in PR. Second part of this would be: If no, then could the PR company pay the NV company a fee to manage the merchant processing, so then it becomes more of a vendor relationship (eg NV charges a 1% fee to manage processing, so all funds flow thru to PR company minus 1%.)

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Samuel Lai

Tax Expert| Tax Planner| Entrepreneur

It depends on the type of business product or service. If it is a service basis company, and all the services have been done by the owners in PR, then the income would be not the U.S source of income.

International tax is one of my expertise. My tax firm, SBS Tax and Consulting Services, works closely with foreigners who own businesses in the U.S. Therefore, I can answer any tax questions you may have.

Answered over 2 years ago