GET GOING NEWSLETTER · June 14, 2026
Most people treat Act 60 as an answer. It is a tool — and only the right tool for certain jobs.
This week I want to walk you through a real case. No names. The client gave me permission to use the structure as a teaching example because he said nobody had explained it to him this clearly before, and he had already talked to two other attorneys.
That tracks with what I see constantly. A lot of content about Act 60. Very little content about when Act 60 is the wrong answer and what you do instead.
CASE STUDY
Act 60, Cook Islands, and the Question That Sounds Simple
A client came to me with a question that sounded straightforward. He already lived in Puerto Rico. He had an Act 60 decree in the pipeline. His plan was to run a litigation finance operation — lending to law firms and plaintiffs in exchange for a share of recoveries — through a Puerto Rico LLC, with the actual lending done through a Cook Islands trust.
The question was: could the profits land in the Puerto Rico LLC under his Act 60 decree?
This is the kind of question that sounds like it has a yes or no answer. It does not.
The first thing I told him: the answer depends entirely on what the Puerto Rico entity actually does in substance — not what the documents say it does. That distinction matters more than anything else in the analysis.
“If the Puerto Rico LLC is genuinely running the financing operation, it is functioning as a financial entity. And Act 60 is not built for financial entities.”
Puerto Rico has a separate regime for this: the International Financial Entity, or IFE, under Act 273. The IFE statute expressly authorizes licensed entities to originate, administer, and service loans and financial transactions from Puerto Rico for nonresidents. It is designed for exactly the kind of structure this client was building.
It is also more burdensome. The current statute sets a general minimum paid-in capital requirement of $10 million, requires at least eight full-time employees including two in compliance, carries a $50,000 application fee, and demands full AML, BSA, Patriot Act, and OFAC compliance infrastructure. None of that is cheap or fast.
That is also precisely why the IFE file is stronger. A licensed financial entity with real staffing, real capital, and real compliance infrastructure presents a much cleaner audit record if OCIF, Hacienda, or another authority ever examines the structure. The burden is the point.
The second path — using the Cook Islands entity as the actual lender while limiting the Puerto Rico LLC to genuine services — is viable, but only within strict limits. The local entity could provide underwriting support, deal sourcing, case screening, portfolio administration, payment processing, and investor reporting. Those activities are defensible as services performed from Puerto Rico.
What that structure cannot do is treat the offshore entity as the lender in form while routing the full economics of the lending position back to Puerto Rico. If the Cook Islands trust provides the capital, owns the receivable, and bears the repayment risk, the principal return belongs to that entity first. The Puerto Rico LLC can earn arm’s length fees for real services. It should not be used as a landing point for offshore lending profits wrapped in an Act 60 label.
Path 1: Puerto Rico entity is the real financing company → pursue an IFE under Act 273. More expensive, takes longer, strongest compliance position.
Path 2: Cook Islands entity is the actual lender → limit Puerto Rico to documented, arm’s length support functions. Keep substance and form consistent.
The client had not been told any of this before. He had read extensively about Act 60 and talked to two other attorneys. Both had treated Act 60 as the default answer without asking what the Puerto Rico entity would actually do. That question — what does the entity do in substance — is where every serious structure analysis has to start.
FROM THE EXCHANGE
How Do Crime Rates Vary Across Countries?
A breakdown of how to read crime data across different jurisdictions — what the numbers actually measure, what they miss, and how to use them as a planning tool rather than a deterrent. Members only.
NEW ON YOUTUBE
The American Dream Has Moved
The math underneath the American Dream has changed. Housing, healthcare, taxes, compliance, and a system that increasingly converts success into paperwork instead of progress. This video makes the case that the dream did not die — it simply moved. Not to another flag or zip code, but to a different structure entirely. One where effort still turns into progress, and wealth means time and options rather than a permanent negotiation with the government.
If the case study above raised questions about structure, this is where the conversation starts.
THIS WEEK’S READ / EDITORIAL
Zcash Plummets 31% Amid Orchard Vulnerability Disclosure
CoinMarketCap
A critical bug in Zcash’s Orchard shielded pool — one that could theoretically allow unlimited counterfeit minting — was disclosed publicly in early June after being discovered during an AI-assisted security audit. ZEC dropped more than 30% in 24 hours, erasing over $3 billion in market cap. Arthur Hayes publicly exited his entire position. The emergency hard fork patched the vulnerability within days. The problem: because of how Zcash’s privacy design works, it is impossible to prove the bug was never exploited in the four years it existed.
A few things worth noting for this audience specifically.
First, the discovery. The vulnerability was found using Claude Opus 4.8 during an AI-assisted audit. That is a meaningful signal about where security tooling is going, and it cuts both ways. AI is going to find things that manual audits miss. That is useful until it is not.
Second, the supply integrity question. Zcash’s value proposition is a hard cap of 21 million coins. The Orchard bug did not invalidate that cap in practice — the fork is patched and the developers believe no exploitation occurred. But the point of a privacy coin is that you cannot prove it. That is the feature and the flaw in the same sentence.
Third, the broader lesson for anyone using crypto as part of an international financial structure. Concentration of financial infrastructure in a single protocol — especially a privacy-focused one with a smaller development community and lower liquidity — carries a risk profile that most people do not fully model. The ZEC story is not a reason to avoid crypto. It is a reason to think carefully about how it sits in the overall structure and what happens if a specific asset reprices by 30% in a day.
The technical patch worked. The trust damage is longer lasting. That is usually how it goes.
PROPERTY SPOTLIGHT
Villa El Alma — Peninsula Papagayo, Costa Rica
$7,500,000 · 3 BD / 3.5 BA · 4,036 sq ft AC / 12,650 sq ft total
Peninsula Papagayo is Costa Rica’s most controlled coastal community — gated, private, adjacent to the Ritz-Carlton Reserve and the Arnold Palmer Ocean Course. Villa El Alma sits on just over an acre within it, ten minutes on foot from Playa Prieta beach.
The residence is 4,036 square feet of air-conditioned living space inside a total construction of 12,650 square feet. Oversized custom teak doors, a sculptural spiral staircase, hand-carved Balinese doors framing Pacific Ocean views. Italian travertine floors, Costa Rican teak finishes, furnishings imported from Bali, Brazil, Canada, and the U.S. — curated by a U.S. interior designer. A black granite infinity pool, heated jacuzzi, and full fiber optic infrastructure.
Three private bedroom suites. The primary suite includes a rooftop garden terrace and a Victoria + Albert soaking tub overlooking the Pacific. Liberia International Airport is 45 minutes out — which makes North American travel routine rather than an event.
This is the kind of property that makes the abstract case for international relocation concrete. The life this represents is available. It is not the default. It is what happens when you decide to stop treating the move as a subject for later.
THE OFFERING
Full 180: Guide to International Relocation
The case study above is what a real decision looks like at a certain level of financial complexity. Full 180 is built for the person who has not reached that level yet but knows they are heading there — or who simply wants to understand what the move actually requires before they decide.
Ten chapters. 7+ hours. How residency works, how to choose a country, how to move your finances, how to run a business abroad, how to bring your family. Free for the current session. 15 spots. Built by someone who did all of this and has been guiding others through it for 18+ years.
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— Christian
Get Going.™