Puerto Rico Acquisition, Merger, or Liquidation

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Multi-State
Control #:
US-CC-18-354B
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Word; 
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This is a multi-state form covering the subject matter of the title.
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FAQ

Puerto Rico corporations are treated as foreign corporations for U.S. income tax purposes. If a U.S. corporation decides to establish its operations in Puerto Rico through a Puerto Rico subsidiary, the latter will not constitute part of the consolidated group for purposes of U.S. income tax returns, since a P.R.

LLCs may be organized by any natural or legal person by filing articles of organization (also referred to as the certificate of formation) in the Puerto Rico State Department.

A Puerto Rico tax return reporting Puerto Rico income and a U.S. tax return is reflected on Form 1040-NR - FileIT.

For foreign tax credit purposes, all qualified taxes paid to U.S. possessions are considered foreign taxes. For this purpose, U.S. possessions include Puerto Rico, the U.S. Virgin Islands, Guam, the Northern Mariana Islands and American Samoa.

A foreign corporation may be engaged in trade or business in Puerto Rico as a division or branch of that foreign corporation, or as a separate corporation or subsidiary.

The income tax rate can be reduced to 1% if the exempt business is engaged in a ?Novel Pioneer Activity.? Act 60 imposes a base period income limitation on the income tax benefits for businesses that were engaged in the eligible activity in Puerto Rico before filing the tax exemption application.

Accounting records must be prepared in ance with the GAAP followed in the United States.

Puerto Rico primarily follows U.S. GAAP for financial reporting. However, some entities in Puerto Rico, especially those under the jurisdiction of the Puerto Rico Financial Oversight and Management Board, may use International Financial Reporting Standards (IFRS).

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Puerto Rico Acquisition, Merger, or Liquidation