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Section 936 exempts U.S.-based companies operating in Puerto Rico and other U.S. possessions from paying federal income taxes on the production of their subsidiaries.
AN ODIOUS AND UNSUSTAINABLE DEBT Puerto Rico is crushed by a debt of about $73 billion, which in relation to the number of inhabitants is ten times the US average figure. The origin of the debt is the colonial status of Puerto Rico and the US monitoring of this territory that was used as a tax haven.
A second result of the change to 936 was that corporations could no longer receive tax-exempt interest income by banking their Puerto Rican profits in US possessions other than Puerto Rico. The rationale for this policy was to end passage of these funds from Puerto Rican banks to other locations or to Eurodollars.
Around $30 billion, or about 42% of Puerto Rico's outstanding debt, is owned by residents of Puerto Rico. They and local businesses are the parties that are most affected by the government cuts and the increased taxes that have been imposed to stabilize the island's finances.
The economy of Puerto Rico is mainly driven by manufacturing, primarily pharmaceuticals, textiles, petrochemicals, and electronics; followed by the service industry, primarily finance, insurance, real estate, and tourism.
PR Code Section 4010.01(ddd) includes a detailed list of the Marketplace Facilitator Activities. Merchants are generally required to collect, report and remit the SUT, unless they are considered non-withholding agents for SUT purposes.