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Posted

We have a client, presently a citizen of Venezuela. He has applied for

U.S./Puerto Rico citizenship, and is waiting and working on that process.

He resides in Puerto Rico (over 2 years), and is treated as a Puerto Rico

resident for tax purposes. He is the sole owner of an LLC (disregarded

entity, he files Sch C) that is a member of a Fl LLC, located in florida. He

does work for business in its Puerto Rico office. The LLC is profitable,

and he draws a salary from the LLC as well. Thus, I believe he is paying

Puerto Rico taxes on his salary, and U.S. taxes on his share of the LLC

profits.

Posted

In order to deduct contributions to the LLC plan he needs to have US compensation, not dividend income from the LLC.

mjb

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