I am a luxury real estate expert, not a financial advisor, tax attorney, or CPA. The timeline below reflects what I observe from the real estate side of Act 60 relocation. Your client's Act 60 attorney manages the legal timeline. I share the practical, on-the-ground perspective.

This is Week 7 of The Act 60 Briefing. We have spent six weeks covering the what and the why of Act 60. This week we cover the when and the how long — because for advisors helping clients plan around capital events, tax year transitions, and portfolio rebalancing, the timeline is not a detail. It is the foundation of the plan.

Here is what the typical Act 60 relocation looks like from start to finish, based on what I observe from the real estate side with hundreds of clients.

The Full Timeline at a Glance: 12 to 18 Months

From the moment a client begins serious evaluation to the day they are fully settled in their Dorado Beach home with their decree in hand and their residency markers established, the typical timeline runs twelve to eighteen months. Some clients move faster. Some take longer. But twelve to eighteen months is the realistic planning window advisors should work with.

With the 2027 rate change approaching, that timeline matters enormously. A client who starts the process in July 2026 is already tight for a 2026 filing. A client who waits until September or October 2026 may not make it. The time to start is now — and the advisor who brings this timeline to their client's attention is adding genuine planning value.

Phase 1: Evaluation and Attorney Engagement (Months 1-2)

The client researches Act 60, runs initial numbers, and decides to explore it seriously. The first concrete step is engaging a qualified Act 60 attorney in Puerto Rico — not a mainland attorney who "knows someone," but a Puerto Rico-based practitioner who has personally processed multiple decrees.

What the advisor can do at this stage: Help the client identify whether their financial profile makes Act 60 worth pursuing. A client with minimal capital gains and no active business income may not see enough benefit to justify the move. A client with $2 million or more in annual capital gains exposure is almost certainly worth a serious conversation.

This is also the stage where I typically enter the picture from the real estate side. Clients who are serious about the evaluation usually want to understand what homes are available and what prices look like before they commit to the legal process. A preliminary property tour often happens during this phase.

Phase 2: Application Preparation and Filing (Months 2-4)

The attorney reviews the client's financial background, tax history, and eligibility. Documents are compiled — tax returns, identification, proof of Puerto Rico banking, background check materials. The attorney prepares the application and submits it through Puerto Rico's Incentives Portal.

What the advisor can do at this stage: Ensure the client's financial documentation is in order. Coordinate with the client's CPA to compile the required tax returns and financial records. Begin discussing capital event timing — if the client has a significant liquidity event or portfolio rebalancing planned, the timing of that event relative to their residency establishment can have meaningful tax implications. Their CPA and Act 60 attorney should be coordinating on this.

Phase 3: Government Processing (Months 4-12+)

This is the longest and least controllable phase. As I have shared in this series, there are only ten government attorneys processing all Act 60 applications. Your client's application is assigned to one of them and moves at that individual's pace. The timeline typically runs six to twelve months from submission to decree approval.

I describe it to clients as a grocery store with ten checkout lanes. You cannot switch lanes if yours moves slowly. A good attorney monitors progress and follows up regularly, but the pace is ultimately determined by the assigned government processor.

What the advisor can do at this stage: This is the waiting phase from a legal standpoint, but it is the action phase from a planning standpoint. While the decree is being processed, the client should be:

• Establishing residency markers: Puerto Rico driver's license, voter registration, local banking, primary care physician, transferring their dog
• Shopping for a home: The property purchase requirement is within two years of decree approval, but most clients purchase in year one to avoid rising prices and to establish the strongest possible residency footprint immediately
• Planning the financial transition: Working with their CPA on the optimal timing for capital events relative to their residency establishment date
• Winding down mainland connections: This is where the Closer Connection Test becomes relevant. The client should be actively shifting their center of gravity to Puerto Rico — and their advisor should understand that this shift is not optional

Phase 4: Decree Approval and Property Purchase (Months 8-14)

The decree is approved. The client now has a legally binding contract with the Puerto Rico government guaranteeing their tax benefits for fifteen years with the option to extend for an additional fifteen. The two-year clock for the property purchase requirement begins.

From the real estate side, this is where my work intensifies. Most of my clients purchase during this phase or have already identified their property during Phase 3. The sweet spot in Dorado Beach is $6 million to $10 million. Most transactions close in cash. Seller financing at 40-50% down with three-to-five-year interest-only terms is also common.

What the advisor can do at this stage: Help the client evaluate the property purchase within their overall asset allocation. As I discussed in Week 5, the required property purchase is not an expense — it is a tax-advantaged investment in a structurally appreciating market. The advisor who frames it that way adds meaningful perspective to the decision.

Phase 5: Settled and Compliant (Month 14+)

The client is living in Dorado Beach. Their decree is active. Their residency markers are established. Their business operations have transitioned. Their family is settled. Their dog is sleeping on the terrace.

From this point forward, the ongoing obligations are straightforward: maintain 183-day physical presence, file required annual reports, make the $10,000 annual charitable contribution, and keep their center of gravity firmly rooted in Puerto Rico. Their Act 60 attorney and CPA manage the compliance. The advisor manages the portfolio. And the client lives their life in one of the most extraordinary communities in the Caribbean.

The 2026 Deadline: Working Backward from January 1, 2027

For advisors whose clients want to lock in the 0% capital gains rate, here is the practical math working backward from the deadline:

• Decree must be filed and residency established in 2026
• Decree processing takes 6-12 months — with only 10 government processors
• Application preparation takes 1-2 months
• Attorney engagement and evaluation takes 1-2 months

That means a client starting the process today — in mid-2026 — is on an aggressive but achievable timeline. A client who waits until fall 2026 is at significant risk of not completing the process before year end.

The bottom line for advisors: if you have a client who fits the Act 60 profile, the most valuable thing you can do right now is not analyze the tax code. It is simply bring it up. Start the conversation. Because the timeline for the most favorable terms is measured in months, not years.

As Always: This Is the Law

The timeline I described above is the process of complying with a legitimate law that has been in place since 2012 and has legislative certainty through 2055. Your client is not doing anything aggressive or creative. They are following the legal process that the Puerto Rico government designed specifically to attract their capital and economic activity. The decree, the residency requirements, the property purchase — all of it is the law working exactly as intended.

Continue the Conversation

If you want to discuss how the relocation timeline intersects with the real estate market — what is available now, how quickly properties are moving, and how to position your client for the strongest possible purchase — I welcome a conversation.

Next Thursday: Week 8 of 15 — The Five Misconceptions Your Clients Will Have About Puerto Rico — And the Real Answers

Frequently Asked Questions

How long does the Act 60 application process actually take?

From attorney engagement to a decree in hand, most of my clients spend twelve to eighteen months. Government processing alone accounts for six to twelve months of that, and it is the portion nobody controls — roughly ten government attorneys handle every Act 60 application, and a file moves at the pace of whichever one receives it. Any advisor promising a guaranteed faster timeline is describing something I have not seen happen.

If a client starts now, can they still lock in the 0% capital gains rate?

It is achievable but tight. The decree must be filed and residency established within the 2026 tax year, and the evaluation and application stages take one to two months each before processing even begins. Clients who started by mid-2026 are on an aggressive but realistic path. Clients starting in the fall are, in my observation, at genuine risk of missing the window. Only the client's Act 60 attorney can assess a specific case.

Does the client have to buy a home as soon as the decree is approved?

No. The requirement is a purchase within two years of decree approval. In practice, most of my clients buy in year one anyway, for two reasons: Dorado Beach inventory in the $6 million to $10 million range is limited and prices have moved consistently, and owning early builds a stronger residency footprint than renting. Waiting the full two years is permitted. It is rarely the better outcome.

What happens if a client cannot meet the 183-day presence requirement in a given year?

This is the question advisors should raise early, because physical presence is not a formality — it is the foundation of bona fide residency, and the obligation continues for the full life of the decree. The consequences of falling short are a legal and tax matter that the client's Act 60 attorney and CPA must address directly. What I can say from the real estate side is that clients who treat Puerto Rico as a genuine home, rather than a mailing address, have an easier time with every part of this process.

Who manages which part of the relocation?

The Act 60 attorney owns the decree — eligibility, application, filing, and ongoing compliance. The CPA owns tax planning, capital event timing, and annual filings. I own the real estate side: what is available in Dorado Beach, what it costs to carry, how transactions are structured, and how a purchase strengthens the residency picture. The advisors I see run the cleanest relocations assemble all three early, rather than routing everything through one generalist.

About Christian Kleiner

Christian Kleiner is the founder & CEO of Christian Kleiner Luxury Real Estate, Puerto Rico's premier luxury real estate brokerage specializing in Act 60 relocation and Dorado Beach luxury properties. A full-time Dorado Beach resident with over 32 years of real estate experience, Christian works with high-net-worth entrepreneurs and investors navigating every aspect of the Act 60 relocation process. He has been featured in Mansion Global, The New York Post, and Yahoo Finance, and was a featured speaker at the 2026 Uncorrelated Alts Conference in Puerto Rico.