Important: When you apply for Act 22/20/60, it is backdated to January 1st of that year. See paragraph 5 of the attached Act 22 decree.
Note that your decree only influences PR tax law. Backdating does not affect the asset sourcing rules or tax bill in the eyes of the IRS. so this fact does not mean, for example, that you will pay 0 tax on US-source assets sold on Jan 1, when you move to PR, establish BFR-PR, and apply for act 60 later that year. the IRS still has a claim to those assets regardless of when your decree is backdated to