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亿万富翁:为避税移居波多黎各要小心

Cyrus Sanati 2013年03月14日

波多黎各拥有迷人的海滩,但当地的政治风险和高犯罪率也不容忽视。像约翰•保尔森这样一心希望避税的美国富人在移居前理应三思而后行。

    在为了避税移居波多黎各之前,亿万富翁约翰•保尔森这些人理应三思。最近,这个加勒比岛国开出了诱人的税收政策,希望吸引美国富人。这些政策看上去不错,但谁也不能保证波多黎各政府长期一定能兑现承诺。

    随着美国本土的社会经济问题日益加深,一些追求安全和稳定的富裕人群已心生去意。但在波多黎各,近几年犯罪率屡创新高,并开始向首都圣胡安的富人区扩散。如今,当地的暴力犯罪和经济低迷都无好转迹象。这样的现实,与波多黎各政府竭力描绘的金融天堂有着天壤之别。

    金融危机已迫使全球政府开始考虑新的创收方式。近几年美国频频动用的是财政刺激政策和印钞机。现在,美国政府正在削减开支和增加税收,导致民怨沸腾,特别是美国纳税人中最富有的2%人群,这些人在加税过程中首当其冲。。

    今年美国收入最高的2%人群承担的长期资本利得和股利税率已从十多年来的15%调高到了近24%。富人们的联邦所得税税率也从35%升到了39.6%。这让美国很多高收入者非常不满,特别是像约翰•保尔森这样的大投资者。据报道,这位曾和很多富人下注约150亿美元、赌美国房地产泡沫会破裂的对冲基金经理正在考虑移民波多黎各,以免支付巨额税单。

    为什么是波多黎各?这个岛国最近通过了一部法律,准许新居民的资本利得税税率以及来自当地业务的所得税税率为零。零税率仅适用于其成为波多黎各居民后进行的投资利得和收益,政策有效期至2035年底。在获得居民身份前的收益和利得,比如一只尚未出售的股票的账面利得,仍需按波多黎各通行的10%资本利得税纳税。如果在十年后出售投资,但仍在2035年底前的政策有效期内,税率可降至5%。

    吸引保尔森的可能是藉此可转移历史投资收益。他显然已经将很多赚的钱重新投入了自己的基金,因此他的大部分财富都没有纳过税。自美国楼市危机以来,他的投资表现不是很出色,但仍有几十亿美元放在基金中,这些钱现在拿不出来,除非向山姆大叔支付一笔巨额税单。

    为了省下几十亿美元,保尔森可能会南下前往波多黎各。成为波多黎各居民,省下大笔税费,填写一份简单的表格,每个日历年度在这个岛国至少居住183天。不像其他的避税计划,保尔森及其家人不一定要放弃美国公民身份,才能享受这一特殊的税收优惠政策,这得益于波多黎各和美国政府独特的税收安排。

    John Paulson and other plutocrats should think twice before moving to Puerto Rico in search of a tax break. While the Caribbean Island's recent push to lure wealthy individuals from the U.S. mainland seems like a great deal, there is no guarantee that the Puerto Rican government will be able to make good on their long-term promises.

    The U.S. territory has a bevy of social and economic problems that appear to be getting worse by the day, making it an inhospitable place for a wealthy individual seeking safety and stability. Crime broke through record highs in the last few years and has started to spill into the wealthy neighborhoods of San Juan, the capital. The violence and economic malaise show little sign of abating. It's a long way from the financial paradise the Puerto Rican government is trying so hard to portray it as.

    The financial crisis has forced governments around the world to think of new and creative ways to generate and retain income. In the U.S., fiscal stimulus and money printing was the name of the game for the first few years. Now the government is slashing spending and raising taxes, much to the chagrin of just about everybody, but especially to the top 2% of U.S. taxpayers who arebearing the brunt of the tax hikes.

    Indeed, the tax rate on long-term capital gains and dividends for the top 2% of earners jumped this year from 15%, where it had been for over a decade, to just under 24%. The wealthy also saw a boost in federal income taxes from 35% to 39.6%. This has made a lot of America's top earners very upset, especially for big-time investors, like John Paulson. The hedge fund manager who made an estimated $15 billion betting against the housing bubble, along with a number of rich investors, is reportedly looking to move to Puerto Rico to avoid getting stuck with a high tax bill.

    Why Puerto Rico? Well, the island recently passed a law allowing new residents to pay zero tax on capital gains and zero tax on income derived from local businesses. This rate applies only to income and gains derived from investments made after the person has become a resident of the island and will last through the end of 2035. Income and gains that accrued before residency was established, but have yet to be taxed, such as paper gains made in a stock that has yet to be sold, will be subject to Puerto Rico's normal 10% capital gains rate. For investments sold after 10 years, but before the end of 2035, the rate drops to 5%.

    Being able to move investment earnings made in the past is probably what grabbed Paulson's attention. He has apparently reinvested much of his winnings back into his fund, so he has not paid taxes on the bulk of his wealth. His investment performance hasn't been so hot since the housing crisis, but he still has billions of dollars left floating in his fund that he can't take out without receiving a big tax bill from Uncle Sam.

    So to save a few billion dollars, Paulson could make the move down south to Puerto Rico. Becoming a resident of Puerto Rico and receiving this tax benefit involves filling out a simple form and living on the island for at least 183 days per calendar year. But unlike other tax avoidance schemes, Paulson and his family don't have to renounce their U.S. citizenship to get the special tax break given Puerto Rico's unique tax arrangement with the U.S.

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