here’s an email from a DEDC lawyer to a member of the facebook group regarding this:
"After reviewing your file, and considering that you moved to Puerto Rico on December 31, 2017 and filed the Act 22 application on 2018 (June 25, 2018), the Grant became effective in 2018.
The effective date of an Act 22 is the year in which the Grantee is considered a bona fide resident of Puerto Rico, but never before the year in which the applicant filed the Act 22 application. The acceptance date of a grant is not a factor to determine its effective date.
In your case, you filed the Act 22 Application in 2018, and precisely, that was the year in which you became a bona fide resident of Puerto Rico (pursuant to the date of residency informed in the Grant’s acceptance). Thus, the Grant became effective in 2018. This means that you have to: (i) file Puerto Rico Tax Return for said year; (ii) file the 2018 Annual Report for the Grant (whether or not you claimed benefits under the Grant in 2018).