We have a client, presently a citizen of Venezuela. He has applied for
U.S./Puerto Rico citizenship, and is waiting and working on that process.
He resides in Puerto Rico (over 2 years), and is treated as a Puerto Rico
resident for tax purposes. He is the sole owner of an LLC (disregarded
entity, he files Sch C) that is a member of a Fl LLC, located in florida. He
does work for business in its Puerto Rico office. The LLC is profitable,
and he draws a salary from the LLC as well. Thus, I believe he is paying
Puerto Rico taxes on his salary, and U.S. taxes on his share of the LLC
profits.