Onshore FeederFund Puerto Rico, tax decree, LP/LLC

Puerto Rico offers significant tax incentive regimes under what is now Puerto Rico Incentives Code (Act 60) (formerly Acts 20/22/185 etc.). Funds and fund-service providers can benefit if they meet certain local-business, resident-investor, or fund-structure requirements.
• By structuring a fund with a Puerto Rico on-shore feeder (or full master-feeder) you can align a tax-efficient domicile with U.S. territory status (i.e., U.S. dollar, U.S. legal infrastructure, etc) which gives a comfort layer for institutional investors.
• This structure can offer an edge: many conventional hedge/PE firms still operate in Delaware, Cayman, Luxembourg etc. Having a domicile in Puerto Rico may differentiate you — especially if you are targeting U.S. taxable investors or want to combine U.S. regulatory comfort with tax optimization.
• For your specific verticals (e.g., Puerto Rico real-estate, Act 60 structures, alternative asset verticals) being domiciled on the island gives you direct local presence, regulatory/regime familiarity, and potential investor appeal (showing you are aligned with Puerto Rico’s growth story).
• Given our umbrella GP structure, multiple specialized LLCs and alignment with Puerto Rico tax incentives (Puerto Rico’s Act 60 for the platform) — a feeder fund domicile there fits very well into this architecture.