In a May 2024 post from Business Insider, Filip De Mott summarizes how the IRS has made little progress “in the abuse of a Puerto Rican tax benefit,” according to a whistleblower.
The U.S. Congress enacted the Corporate Transparency Act (the "Act"), which went into effect on January 1, 2024. The Act creates another tool in the fight against illegal financial activity. The Act requires "reporting companies" to disclose certain information about their "beneficial owners." The U.S. Treasury enforces the Act through the Financial Crimes Enforcement Network ("FinCEN"), which issued regulations. Under the Act, the term "State" includes Puerto Rico.
In today's globalized economy, multinational corporations often establish subsidiaries in various countries to expand their operations and take advantage of favorable business environments and tax haven countries. However, this practice has given rise to challenges in international tax regulation, leading to additional anti-deferral regimes that have dramatically expanded in recent years, mainly attributable to the enactment of the Tax Cuts and Jobs Act in 2017 (TCJA) under the Trump administration. The TCJA introduced a significant overhaul to the U.S. tax landscape, ushering in new requirements and categories of foreign income inclusions that have notably affected U.S. shareholders by creating the concepts of Controlled Foreign Corporations (CFCs) and Passive Foreign Investment Companies (PFICs). This article aims to provide a comprehensive overview of CFCs and their implications for businesses to ensure compliance and navigate this complex world.
Este pasado martes, 3 de octubre, el Lic. Antonio Bauzá y la Lic. María Gabriela Diez, dieron una charla a los estudiantes de la Escuela de Derecho de la Universidad Interamericana sobre la importancia del derecho corporativo.
The following explores the concept of Series LLCs, their creation, benefits, risks, and legal considerations. Series LLCs offer an attractive structure for businesses with multiple assets, providing the advantages of separate liabilities without the complexities of maintaining multiple entities.
The Section on Environment, Energy & Resources (SEER) of the American Bar Association (ABA) has recently named our partner, Guillermo Silva, as planning chair of its Disaster Recovery and Resilience Conference to be held in San Juan, Puerto Rico, on February 8, 2024.
The U.S. Congress enacted the Corporate Transparency Act (the “Act”) as part of the National Defense Authorization Act for Fiscal Year 2021. The Act goes into effect on January 1, 2024.
