Tax in Puerto Rico

McConnell Valdés LLC

Comprehensive in scope, McConnell Valdés LLC fields a standalone tax department, which also includes a tax litigation practice and a non-profit organisations practice group. It places a key focus on tax incentives, an area in which the team excels, with special expertise in industrial services, tourism, hospital, energy, agriculture, aviation and private equity-sector clients. Practice head Isis Carballo-Irigoyen particularly stands out for her niche knowledge of Puerto Rico Act 154, applicable to multinational manufacturing companies, and of proceedings with the Puerto Rico Treasury Department and foreign jurisdictions to prevent double taxation. Retail and e-commerce are other areas of particular interest, in which the firm assists Puerto Rico and US companies.

Practice head(s):

Isis Carballo-Irigoyen

Key clients

Lutron

Namco USA

Fresenius

Cooper Vision Caribbean

Dow Du Pont

IPR Pharmaceuticals

Shell Trading (US) Company

Abbott/St. Jude Medical

Ingersoll Rand

PPG Industries

The Coca Cola Company

Google

Johnson & Johnson

T‐Mobile

UBS

Hewlett Packard

Work highlights

  • Assisting several multinational companies with the legal and tax implications of a government-mandated lockdown due to Covid‐19, including negotiating with the government on lockdown exemptions for the manufacturing sector.
  • Assisted Bank of Nova Scotia with the sale of its Scotiabank Puerto Rico operations to Oriental Bank.
  • Provided T-Mobile with tax advice on the T‐Mobile and Sprint combination.

O'Neill & Borges

O'Neill & Borges has tax advice as one of its main strengths, and as such covers all aspects of tax matters. On the non-contentious side, the group's offering covers income, sales, property and municipal taxes, as well as tax incentives for clients operating in the manufacturing, technology, energy, agriculture and aviation sectors, among others. The department's tax expertise is also relevant in matters of reorganisations, liquidations and other corporate transactions. Tax litigation is another very active area for the firm. Rosa González-Lugo has a main focus on corporate taxation, tax exemptions and M&A-related tax matters. Ismael Vincenty-Medina's practice centres on tax audits and negotiations. The firm's tax litigators include Amaya Iraolagoitia, who often represents clients in administrative and judicial procedures.

Pietrantoni Méndez & Alvarez LLP

Pietrantoni Méndez & Alvarez LLP's broad tax practice is sought out by local and US entities, financial institutions and high-net-worth individuals alike. The group offers a full service in the tax sphere, with particular strength in tax planning, reorganisations and tax exemptions, where it regularly acts for clients in the tourism sector, in particular. Puerto Rico and federal income taxation, and corporate and partnership taxation are key pillars for the department and are among the main focus areas for Dianette Rivera-Meléndez and Edgar Ríos-Méndez. Counsel and litigator Fernando Goyco-Covas is noted for his expertise in mutual funds structuring, investment vehicles and tax-exempt operations.

Adsuar Muñiz Goyco Seda & Pérez-Ochoa

Adsuar Muñiz Goyco Seda & Pérez-Ochoa assists companies entering Puerto Rico with matters of local and international tax regimes, exemption and incentives, and also advises corporations on employee benefits and M&A-related tax matters. Practice head Ricardo Muñiz stands out for his private client tax practice, and his expertise in estate tax and planning, trusts, inheritance and pensions.

DLA Piper Puerto Rico

At DLA Piper Puerto Rico, Manuel López-Zambrana leads the experienced tax team and assists clients in structuring a variety of transactions, including private equity deals, corporate acquisitions and disposals. He and his team are particularly active in international tax matters, transfer pricing and indirect tax, and also represent clients in tax controversies and disputes. In addition, applications for tax exemptions, the creation of tax structures for energy microgrids and the US tax implications of cross-border acquisitions feature prominently in the group's workload.

Practice head(s):

Manuel López-Zambrana

Key clients

Puerto Rico Public-Private Partnership Authority

Nagnoi

University of Puerto Rico

Banco Popular de Puerto Rico

Puerto Rico Banking Association

RioBlanco Capital

Sonnedix UK Services Limited

Bancredito International Bank

Biomass Green Fuels

UBS Trust Company of Puerto Rico

Work highlights

  • Advising the Government of Puerto Rico on various US and Puerto Rico tax legislative and regulatory initiatives to attract manufacturing operations to the island.
  • Assisting Quanta Services and ATCO in their new joint venture, LUMA Energy, in the $1.6bn PPP transaction to operate and maintain the transmission and distribution of assets of the Puerto Rico Electric Power Authority, including providing advice on tax aspects.

Ferraiuoli LLC

Ferraiuoli LLC founder Pedro Notario leads the firm's corporate tax practice group. He and his team handle tax exemptions, credits and due diligence matters. A second service line is coordinated by Rene Aviles, who heads the employee benefits and the estate and trusts practice groups. These teams place their respective focuses on employee benefits during corporate transactions, pension administration, and estate tax for private clients. Angel Morales-Lebrón is a key member of the group and an expert in acquisitions and partnership income taxes. Emmanuel Loubriel is a name to note at the associate level.

Goldman Antonetti & Córdova

Goldman Antonetti & Córdova's experienced tax team is often consulted by other departments at the firm in connection to a vast number of matters. Corporate, sales, local and state tax matters are covered by Rebecca Cuevas-Fontán together with financial analysis, tax planning and investments. Of counsel Roberto Montalvo-Carbia has an in-depth understanding of municipal tax matters and their impact on oil and gas companies. The group's tax offering is completed by its knowledge of employee benefits, trusts, income and international tax, as well as reorganisations, compliance and US customs.

Casillas Santiago & Torres LLC

Luis Torres-Marrero is in charge of Casillas Santiago & Torres LLC's tax department, which is known for its expertise in corporate tax and for regularly assisting clients in their negotiations with Puerto Rico's treasury department. Tax incentives, tax planning and compliance are other areas of particular interest.

Reichard & Escalera

Reichard & Escalera often provides tax advice to foreign and local entities in connection to income tax, municipal tax, tax exemptions and tax planning. M&A, spin-offs and audit support represent another significant part of the practice, and are among practice head Carlos Serrano's main areas of activity.

Toro Colón Mullet, P.S.C.

Toro Colón Mullet, P.S.C. has a prominent tax and incentives department, which regularly provides advice to firms in the industrial, tourism, film, solar energy and real estate sectors. Providing both in and out-of-court assistance, Waldemar Fabery-Villaespesa is an expert in income tax, tax incentives and matters connected to tourism developments; he also provides tax advice in the context of M&A and financing deals, and acts as chair of the department.