Tax in Puerto Rico

McConnell Valdés LLC

The powerhouse team at McConnell Valdés LLC remains a marker leader, advising domestic corporates, household-name financial institutions (such as UBS) and global brands (including Google, Coca-Cola, Shell and Hewlett Packard) on a diverse spectrum of tax matters. With a client base spanning sectors ranging from chemicals, tech and pharmaceuticals to retail, beverages, telecoms and energy, the practice’s comprehensive service covers tax incentives and exemptions, consumption tax, advice for non-profit organisations on the structuring and establishing of operations in Puerto Rico, tax litigation and the tax aspects of M&A and deal structuring. The practice is headed by tax practice chair Isis Carballo-Irigoyen, who assists with start-up operations, reorganisations, acquisitions, financings and competent authority proceedings before the Puerto Rico Department of Treasury and the Internal Revenue Service, and vice-chair Yamary González-Berríos, who specialises in corporate and partnership tax. Other key figures include Rubén Méndez-Benabe, who represents clients in tax controversy and litigation matters, including tax audits and examinations, administrative appeals and court proceedings, and Lillian Toro-Mojica, who advises on employee benefits, and income and property taxes.

Responsables de la pratique:

Isis Carballo-Irigoyen; Yamary González-Berríos


Les références

‘The group’s technical knowledge, expertise, key contacts and industry experience make it an amazing tax consulting resource.’

‘Isis Carballo is the best tax resource I have known in my career of 40+ years.’

Principaux clients

Lutron


Sunnova Energy Corporation


Fresenius


CooperVision Caribbean


Celanese


Amgen


Shell


Abbott Ingersoll Rand


PPG Industries


The Coca-Cola Company


Google


T-Mobile


Sears/Kmart


UBS


Hewlett Packard


Principaux dossiers


  • Providing Sunnova Energy with regular advice on the structuring of its Puerto Rico operations and with the application of Puerto Rico tax incentives for its renewable energy operations.
  • Structuring Shell’s Puerto Rico business in an excise tax-efficient manner, taking advantage of the benefits of operating in a foreign trade zone and under the provisions of a tax incentives grant.
  • Providing tax advice to Turkish company Enka, related to the design, procurement and construction of the San Juan Bay Piers under the terms of a public-private partnership with the Puerto Rico Ports Authority.

O'Neill & Borges

The market-leading team at O'Neill & Borges advises insurers, government agencies and multinational corporates across sectors ranging from financial services, consumer products, healthcare and manufacturing to real estate, tech, energy, telecoms and hospitality, on the full range of tax matters. The practice’s comprehensive service covers the tax aspects of M&A, the determination of tax-efficient structures, administrative procedures, tax incentives, transactional work related to bond issuances and financing transactions, tax registrations and compliance, pension and employee benefits, and tax litigation challenging tax impositions by the Puerto Rico Secretary of the Treasury, the Municipal Revenue Collection Centre and various municipalities. The practice is headed by Amaya Iraolagoitia, who brings expertise in tax exemptions related to industrial and renewable energy projects, and who provides representation in judicial and administrative tax procedures, and Rosa González-Lugo, who draws on over three decades' experience in tax planning and structuring, and in tax compliance matters related to commonwealth and municipal taxes. Other key figures include Cristina Morazzani-Jové, who specialises in tax issues related to market entry; Michelle Marichal-Soderberg, who negotiates economic incentives contracts with the Department of Economic Development and Commerce of Puerto Rico; Denisse Ortiz-Torres, who advises financial vehicles on the creation of private equity funds; and Odalys Fuentes Cruz, who was promoted to partner in December 2023.

Responsables de la pratique:

Rosa González-Lugo; Amaya Iraolagoitia


Principaux clients

Financial Oversight and Management Board for Puerto Rico (FOMB)


Evertec


Acrecent Financial Corporation


BayBoston Managers


Columbia College Corporation/National College of Business and Technology Company


Becton Dickinson


Puma Energy Caribe


Costco Wholesale Corporation


LionGrove Management/Rio Mar Hospitality Holdings


Toyota Credit de Puerto Rico


Principaux dossiers


  • Advising the Financial Oversight and Management Board for Puerto Rico (FOMB) on tax matters relating to the restructuring of the Commonwealth of Puerto Rico, including the preparation of tax disclosures related to the restructuring plans, and the legal analysis of the enactment of several new laws, regulations and guidelines.
  • Represented Columbia College Corporation in connection with the purchase of, and merger with, the National College of Business and Technology Company, a Puerto Rico corporation which operates the university known as ‘NUC University’.
  • Advised Sygnus Credit Investments and Acrecent Financial on an internal restructuring transaction.

DLA Piper Puerto Rico

The experienced team at DLA Piper Puerto Rico brings expertise to advising insurers, domestic financial institutions and multinational corporates (including Citibank, Southwest Airlines and Air Canada) on tax planning and structuring, transfer pricing, complex financial transactions, tax audits and appeals, and tax litigation. The group’s active client base spans sectors ranging from aviation, financial services and energy to food and beverages, tech and telecoms. The team is led by Manuel López-Zambrana, an expert in tax controversies who assists clients with complex US federal and Puerto Rican income tax matters and with obtaining Puerto Rican tax incentives for manufacturing and IP licensing activities. Other key figures include of counsel Edwin Figueroa Alvarez, who provides support to start-ups and businesses on the tax aspects of local market entry.

Responsables de la pratique:

Manuel López-Zambrana


Les références

‘Its main strength is its deep bench and the experience of its partners.’

‘Manuel López-Zambrana stands out for his reliability, responsiveness and knowledge.’

Principaux clients

Fundación Ángel Ramos


John Hancock


Southwest Airlines


FirstBank Puerto Rico


Air Canada


Citibank


Sunrun


Preferred Capital Management


University of Puerto Rico


FV Bank International


Tea


Puerto Rico Banking Association


RioBlanco Capital


Stonecrest Investment Management


Nagnoi/Ingenia Health


Principaux dossiers


  • Advised Fundación Ángel Ramos on securing a closing agreement with the Puerto Rican tax authorities to obtain relief from a condition that placed an unreasonable burden on its ability to assign contributions to other not-for-profit entities.
  • Advised the University of Puerto Rico on the establishment of a new defined contribution retirement plan in order to close the current defined benefit retirement plan.