News & Analysis as of

Internal Revenue Service Puerto Rico Income Taxes

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Littler

Puerto Rico Department of the Treasury Announces 2025 Limits on Qualified Retirement Plans

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On January 23, 2025, the Puerto Rico Department of the Treasury issued Internal Revenue Circular Letter No. 24-01 (CL IR 24-01) announcing the applicable 2024 limits for Puerto Rico qualified retirement plans. Pursuant to...more

Mayer Brown

Going in Circles: The IRS Limits Puerto Rico Source Rules in Responding to Aggressive Tax Positions

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The tax advantages for US individuals who become bona fide residents of US possessions can be substantial. These tax advantages have lured more than a few taxpayers to take unreasonably aggressive positions that they are...more

Holland & Knight LLP

Contract Allocations and Judicial Doctrines

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In Cotto-Vázquez v. United States, CIV. NO.: 16-2807 (SCC) (D.P.R. March 11, 2021), Miguel Ángel Cotto-Vázquez (Cotto),1 the former four-time Puerto Rican boxing champion, became involved in another fight. This time he faced...more

Holland & Knight LLP

When Is a Tax Return "Filed"?

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In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Puerto Rico’s Taxation of Severance Payments

Employers considering reductions in force in Puerto Rico should be aware that the rules on the taxation of severance pay in the United States and Puerto Rico are different. The U.S. rule is straightforward: severance pay...more

Littler

Puerto Rico Qualified Retirement Plans: Treasury Eliminates Form 480.70(OE) Filing Requirement for Plan Years Beginning on January...

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On March 11, 2016, the Puerto Rico Department of the Treasury (“PR Treasury”) issued Administrative Determination No. 16-05 (“AD 16-05”), eliminating the requirement to file PR Treasury Form 480.70(OE) for retirement plans...more

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