April 21, 2025
Ms. Velázquez (for herself, Ms. Ocasio-Cortez, and Mrs. Ramirez) introduced the following bill; which was referred to the Committee on Ways and Means
To amend the Internal Revenue Code of 1986 to modify the application of the sourcing rules for digital asset income of Puerto Rican residents.
Section 1. Short title
This Act may be cited as the Fair Taxation of Digital Assets in Puerto Rico Act of 2025
.
Sec. 2. Treatment of digital asset income by Puerto Rican residents
(a) In general
Section 865 of the Internal Revenue Code of 1986 is amended by redesignating subsections (i) and (j) as subsections (j) and (k) and by inserting after subsection (h) the following new subsection:
(i) Digital asset income of Puerto Rican residents
(1) In general
Notwithstanding any other provision of this title, in the case of an individual described in section 933, any income derived in connection with—
(A)
any receipt of any digital asset in connection with—
(i)
mining, staking, or any similar activity with respect to any digital asset, or
(ii)
holding any digital asset (including any fork or air drop of any digital asset), or
(B)
any sale, exchange, or other disposition of a digital asset,
shall not be treated for purposes of this title as derived from sources within Puerto Rico.
(2) Treatment of financial interests
For purposes of this subsection, any financial interest in a digital asset shall be treated as a digital asset.
(3) Digital asset
For purposes of this subsection, the term
digital assetmeans any digital representation of value which is recorded on a cryptographically-secured distributed ledger.
(b) Effective date
The amendment made by this section shall apply to taxable years beginning after the date of the enactment of this Act.