On March 29, 2020, the Puerto Rico Department of the Treasury
(commonly known by its Spanish name, Departamento de Hacienda
de Puerto Rico, or Hacienda) issued Circular Letter of Internal Revenue No. 20-23
(CL 20-23), which extends to coronavirus-related distributions
under qualified retirement plans (CRDs) essentially the same
eligibility requirements, due dates, and local tax treatment that
Hacienda established in Circular Letter 20-09 (CL 20-09) for
distributions under qualified retirement plans related to the
earthquakes that hit Puerto Rico during the beginning of the year
(ERDs).
CL 20-23 is the second item of retirement plan guidance from
Hacienda in less than two weeks in response to the COVID-19
pandemic. On March 24, 2020, Hacienda released Administrative Determination No. 20-09, which
extended due dates for filing the local informative return on
qualified retirement plan distributions and depositing with
Hacienda the Puerto Rico income taxes withheld at
