????在為了避稅移居波多黎各之前，億萬(wàn)富翁約翰?保爾森這些人理應(yīng)三思。最近，這個(gè)加勒比島國(guó)開(kāi)出了誘人的稅收政策，希望吸引美國(guó)富人。這些政策看上去不錯(cuò)，但誰(shuí)也不能保證波多黎各政府長(zhǎng)期一定能兌現(xiàn)承諾。

????隨著美國(guó)本土的社會(huì)經(jīng)濟(jì)問(wèn)題日益加深，一些追求安全和穩(wěn)定的富裕人群已心生去意。但在波多黎各，近幾年犯罪率屢創(chuàng)新高，并開(kāi)始向首都圣胡安的富人區(qū)擴(kuò)散。如今，當(dāng)?shù)氐谋┝Ψ缸锖徒?jīng)濟(jì)低迷都無(wú)好轉(zhuǎn)跡象。這樣的現(xiàn)實(shí)，與波多黎各政府竭力描繪的金融天堂有著天壤之別。

????金融危機(jī)已迫使全球政府開(kāi)始考慮新的創(chuàng)收方式。近幾年美國(guó)頻頻動(dòng)用的是財(cái)政刺激政策和印鈔機(jī)。現(xiàn)在，美國(guó)政府正在削減開(kāi)支和增加稅收，導(dǎo)致民怨沸騰，特別是美國(guó)納稅人中最富有的2%人群，這些人在加稅過(guò)程中首當(dāng)其沖。。

????今年美國(guó)收入最高的2%人群承擔(dān)的長(zhǎng)期資本利得和股利稅率已從十多年來(lái)的15%調(diào)高到了近24%。富人們的聯(lián)邦所得稅稅率也從35%升到了39.6%。這讓美國(guó)很多高收入者非常不滿，特別是像約翰?保爾森這樣的大投資者。據(jù)報(bào)道，這位曾和很多富人下注約150億美元、賭美國(guó)房地產(chǎn)泡沫會(huì)破裂的對(duì)沖基金經(jīng)理正在考慮移民波多黎各，以免支付巨額稅單。

????為什么是波多黎各？這個(gè)島國(guó)最近通過(guò)了一部法律，準(zhǔn)許新居民的資本利得稅稅率以及來(lái)自當(dāng)?shù)貥I(yè)務(wù)的所得稅稅率為零。零稅率僅適用于其成為波多黎各居民后進(jìn)行的投資利得和收益，政策有效期至2035年底。在獲得居民身份前的收益和利得，比如一只尚未出售的股票的賬面利得，仍需按波多黎各通行的10%資本利得稅納稅。如果在十年后出售投資，但仍在2035年底前的政策有效期內(nèi)，稅率可降至5%。

????吸引保爾森的可能是藉此可轉(zhuǎn)移歷史投資收益。他顯然已經(jīng)將很多賺的錢重新投入了自己的基金，因此他的大部分財(cái)富都沒(méi)有納過(guò)稅。自美國(guó)樓市危機(jī)以來(lái)，他的投資表現(xiàn)不是很出色，但仍有幾十億美元放在基金中，這些錢現(xiàn)在拿不出來(lái)，除非向山姆大叔支付一筆巨額稅單。

????為了省下幾十億美元，保爾森可能會(huì)南下前往波多黎各。成為波多黎各居民，省下大筆稅費(fèi)，填寫一份簡(jiǎn)單的表格，每個(gè)日歷年度在這個(gè)島國(guó)至少居住183天。不像其他的避稅計(jì)劃，保爾森及其家人不一定要放棄美國(guó)公民身份，才能享受這一特殊的稅收優(yōu)惠政策，這得益于波多黎各和美國(guó)政府獨(dú)特的稅收安排。

????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.