KNOWLEDGE AND EXPERIENCE IN PUERTO RICO TAX INCENTIVES

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TAX INCENTIVES
& TAX CONSIDERATIONS

Our attorneys have knowledge and experience working with Puerto Rico’s tax credit and tax incentives programs and guide our clients through the same, to identify which of the programs their companies will benefit the most from.  We have extensively advised our clients in connection with the new Puerto Rico Incentives Code, Act No. 60 of July 1, 2019, which grouped the requirements under previous tax incentives laws, to qualify for tax benefits and credits, eligibility requirements, and grant application process for the different programs available under Act 60-2019, as amended. We also provide counsel on the sale and purchase of tax credits granted under local law.

Our transactional practice enables us to pinpoint potential tax issues on the formation, operation, restructuring and disposition of business entities on the island, so that clients can plan for the future. Additionally, we offer careful planning of corporate structure and provide advice on the different tax considerations that are indispensable to the success of local business operations. We have also advised international financial entities on requirements under FATCA and the Foreign Bank Account Report (FBAR).

SOME OF OUR TAX SPECIALTY AREAS AND SERVICES INCLUDE:

  • Advise individuals and companies with respect to requirements to benefit from incentives available under Act 60-2019, the Puerto Rico Incentives Code, including opportunity zones, and previous incentives laws in the topics of manufacturing (Act 73-2008), export services (Act 20-2012), individual investors (Act 22-2012), film (Act 27-2011), energy (Act 83-2010), tourism (Act 74-2010), international financial entities (Act 273-2012), international insurance companies (Act 399-2004), private equity funds (Act 185-2014), among others, and negotiate tax exemption grants on their behalf.
  • Respond inquiries related to IRS filings, such as the FBAR and under FATCA.
  • Provide advice on the different tax considerations in the development and implementation of corporate structures, on federal and Puerto Rico tax matters, also including municipal and local tax matters.

Representative Experience

  • Act as counsel in filing and negotiating multiple tax incentive applications on behalf of clients, under Puerto Rico’s Code of Incentives, Act No. 60-2019 (and previous incentives laws), and successfully obtained decrees for tax incentives related to tourism, the film industry, export services, individual foreign investors, physicians, and young entrepreneurs, among others.
  • Participated in the comment process for the regulation proposed by the Puerto Rico Department of Economic Development and Commerce under Act 60-2019, the Incentives Code Regulation.
  • Advise international financial entities on FATCA and FBAR issues.

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