Puerto Rico's Act 60 tax incentive comes with conditions that decree holders must meet to keep the benefits, according to published guidance on the program. To qualify, a company must secure a decree from the Department of Economic Development and Commerce, known as the DDEC.^[1] The LLC must conduct business in Puerto Rico, and the owner must be a Puerto Rico resident or become one.^[2] Decree holders must also purchase a primary residence within two years of decree approval.^[3] Once granted, the decree carries a central benefit: dividend distributions are 100% exempt from Puerto Rico income tax during the term of the decree.^[4] Guidance for the program states that businesses must be structured correctly from the beginning to benefit.^[5] The read here is that the residency and home-purchase clauses are where a decree lives or dies. More than 50% of graduates from Puerto Rico specialize in technical fields, per program materials tied to the island's opportunity pitch.^[6]