Act 60 CPA vs lawyer: scope, fees, and ongoing work

At a glance

Legal work

Usually one time for a defined application scope

Application charges

One-time government and transaction costs

Accounting and payroll

Monthly or periodic

Tax compliance

Annual

Donation

Recurring personal obligation for an applicable investor decree

Best control

A written responsibility matrix

Divide the professional scopes

Plan the one-time costs

One supplied legal engagement produced the following rounded planning example. It is not a market-wide price or a public provider fee schedule.

Plan the recurring costs

A supplied CPA discussion estimated about $2,000 per year for annual tax and Act 60 compliance filings and about $500 per month for combined accounting and payroll. A later combined scope was about $520 per month.

• Do not treat a combined monthly quote as separate published accounting and payroll prices.
• If payroll is separated, request an accounting-only CPA quote and a payroll-provider quote.
• Confirm that the CPA will reconcile payroll prepared by the outside provider.
• Keep annual government charges and personal obligations outside professional-fee totals.

Separate fees from obligations

The supplied planning assumptions included a $10,000 annual charitable donation and a residence purchase within two years for the applicable Chapter 2 grant. Confirm the governing cohort, timing, and actual decree before relying on those figures.

Map the annual compliance work

The supplied CPA discussion grouped five business filings into one annual engagement: municipal license tax, Puerto Rico income tax, personal property tax, the Act 60 compliance report, and the annual LLC filing or fee coordination.

• Confirm whether federal business and individual returns are included.
• Confirm whether extensions, notices, amendments, and prior-period cleanup are included.
• Confirm who tracks deadlines and provides the data used in the annual Act 60 report.

Build a responsibility matrix

1. 1

   List every deliverable

   Include formation, EIN, SURI, municipality, permit, application, books, payroll, returns, annual compliance, donations, and property evidence.

2. 2

   Assign one owner

   Mark the lawyer, CPA, payroll provider, or client as responsible for each task.

3. 3

   Mark the pricing

   Record whether each task is included, excluded, hourly, flat, monthly, or separately billed.

4. 4

   Connect the firms

   Authorize direct coordination where an application, registration, payroll record, or annual filing crosses scopes.

Common questions

Do I need both an Act 60 lawyer and a CPA?

Neither title should be treated as a substitute for a defined scope. Legal application and interpretation work usually sits with the lawyer; books, payroll, and returns usually sit with the CPA. Many applicants engage both because the responsibilities differ.

Is the decree application fee annual?

No. The application filing charge is a one-time application cost. Annual reports, professional compliance work, and applicable personal obligations are separate recurring items.

How much should I budget for combined Chapter 2 and Chapter 3 legal work?

The supplied engagement produced a rounded example of about $24,000 for combined legal fees, application fees, affidavits, and notarization. Treat it as one dated example, not a market rate.

Can I infer accounting-only cost from a combined monthly quote?

No. Ask for an accounting-only scope. A calculator allocation or subtraction from a combined quote is not a provider quote.

Who should file the annual Act 60 compliance report?

Either professional may offer it, but the CPA often already holds the financial records. Assign it explicitly so it is not omitted or purchased twice.

Sources and verification

Rules, prices, locations, and provider coverage can change. These links are the primary or first-party pages checked for this guide.

• Puerto Rico Act 60 code — Verify the current consolidated law and the actual decree.
• Stolberg Law — Provider referenced in the supplied legal engagement.
• Thriv CPA — Provider referenced in the supplied accounting materials.
• EasyChecksPR — Independent Puerto Rico payroll option.
• Puerto Rico Treasury.
• Puerto Rico Department of State: Registration of Legal Entities.