ns to override the Section 865(gX2) 10% minimum tax requirement for capital gains of Puerto Rico residents, who are generally subject to U.S. tax on non-Puerto Rico source income, including U.S. source income. The TAMRA legislative history notes, without explanation, that the Treasury authority to promulgate su

gn markets are services performed for nonresident individuals or foreign entities that have no nexus with Puerto Rico. Services provided for a U.S., non-Puerto Rico client would qualify. In other words, the eligible service is not, and will not be, related to the conduct of a trade, business, or other activity