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Senators Say Lawyers Helped Wealthy Clients Dodge Taxes in Puerto Rico

used it to avoid taxes on income earned within the 50 U.S. states. The I.R.S. has identified about 100 people who may have improperly avoided federal income taxes after their moves to Puerto...

NYTIMES 입력 2026.04.30 18:06 0

Senators Say Lawyers Helped Wealthy Clients Dodge Taxes in Puerto Rico

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Senators Say Lawyers Helped Wealthy Clients Dodge Taxes in Puerto Rico

Rich Americans are writing off taxes they owed before they moved to Puerto Rico, the Senate Finance Committee says.

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Dan Morehead, founder of the cryptocurrency investment firm Pantera Capital. Shortly after he relocated to Puerto Rico in 2021, his company sold a large position, generating capital gains of more than $1 billion.

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Xavier Garcia/Bloomberg

Jesse Drucker

April 30, 2026,

5:04 a.m. ET

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A Senate committee examining potential abuses of a lucrative Puerto Rico tax break by wealthy Americans is asking the Internal Revenue Service to investigate the role played by two prominent lawyers who advised on several of the transactions, according to a letter reviewed by The New York Times.

The request is part of

an investigation

by the Senate Finance Committee into whether wealthy Americans who moved to Puerto Rico to take advantage of a special tax break, known as Act 60, improperly used it to avoid taxes on income earned within the 50 U.S. states. The I.R.S. has identified about 100 people who may have improperly avoided federal income taxes after their moves to Puerto Rico.

Senator Ron Wyden, an Oregon Democrat, sent a letter on April 29 to Jarod Koopman, the I.R.S.’s chief tax compliance officer, asking the agency to review legal advice given to some of those people by Jeffrey Rubinger and Summer LePree, two former partners at the international law firm Baker McKenzie.

“I am concerned that numerous investors used these legal opinions from Rubinger and LePree to avoid federal income taxes on large capital gains that accrued prior to relocating to Puerto Rico,” Mr. Wyden wrote.

Many wealthy Americans have moved to Puerto Rico to take advantage of the tax break, which treats capital gains income generated there as exempt from federal income tax. Last year, the

Senate committee wrote

to Dan Morehead, founder of Pantera Capital, one of the biggest cryptocurrency investment firms, as part of its inquiry into whether he abused the tax law.

The Justice Department and the criminal investigation division of the I.R.S. are investigating the two former partners,

Bloomberg previously reported

, and Baker McKenzie received a grand jury subpoena from the U.S. attorney’s office in Miami asking for records about the lawyers’ work on “Puerto Rico tax planning” structures.

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