US Multinationals in Puerto Rico and the Repeal of Section 936 Tax Exemption for U.S. Corporations

US Multinationals in Puerto Rico and the Repeal of Section 936 Tax Exemption for U.S. Corporations
Author: Zadia Maria Feliciano
Publisher:
Total Pages: 28
Release: 2017
Genre: Economic assistance, American
ISBN:

Puerto Rico, the Commonwealth Island and unincorporated territory of the United States, was placed under a fiscal Oversight Board by the U.S. Congress in 2016. Unable to pay $72 billion it owes to bond holders, Puerto Rico's Government and the Oversight Board filed for court proceedings under Title III of the Puerto Rico Oversight, Management and Economic Stability Act, similar to Chapter 9 of the US Bankruptcy code. The origins of the crisis in Puerto Rico have been attributed in part to the phase out of the IRS Section 936 tax exemption program for U.S. corporations from 1995 to 2005 and its elimination in January 2006. Using industry panel data, compiled from the IRS Statistics of Income for U.S. Possessions Corporations, the U.S. Economic Census for Outlying Areas, and the mainland U.S. Economic Census, we analyze the effects of the phase out and elimination of Section 936 on the number of establishments, value added, employment, and wages in Puerto Rico's manufacturing. Our results show the elimination of Section 936 had the effect of decreasing average manufacturing wages by 16.7%, and decreasing the number of manufacturing establishments by 18.7% to 28.0%

Puerto Rico and the Section 936 Tax Credit

Puerto Rico and the Section 936 Tax Credit
Author: Mary Ellen O'Toole
Publisher: DIANE Publishing
Total Pages: 74
Release: 1994
Genre:
ISBN: 9780788102110

The Section 936 tax credit primarily affects Puerto Rico and the subsidiaries of U.S. companies that operate there. Under this section, income earned by U.S. firms from operations in U.S. possessions is effectively exempt from federal corporate income taxes. This comprehensive report reviews all aspects of Section 936. 30 charts and tables.

Tax Policy

Tax Policy
Author: United States. General Accounting Office
Publisher:
Total Pages: 72
Release: 1993
Genre: International business enterprises
ISBN:

Tax Policy

Tax Policy
Author: James A. Wozny
Publisher: DIANE Publishing
Total Pages: 64
Release: 1998-04
Genre: Business & Economics
ISBN: 9780788147746

Provides information on economic activity in Puerto Rico, before and after the recent changes in U.S. tax benefits for corporations operating there. Presents information on the recent trends in Puerto Rico's principal economic indicators; investments by U.S. corporations in Puerto Rico that generate tax-exempt, nonbusiness income; and investment and employment promoted by Puerto Rico's Economic Development Administration (EDA). Utilizes economic data obtained from the Puerto Rican Planning Board, Puerto Rico's Commissioner of Financial Institutions, the EDA, and other agencies. Charts and tables.

Intangible Assets, Corporate Taxes and the Relocation of Pharmaceutical Establishments

Intangible Assets, Corporate Taxes and the Relocation of Pharmaceutical Establishments
Author: Zadia M. Feliciano
Publisher:
Total Pages: 0
Release: 2021
Genre:
ISBN:

Puerto Rico operated as a tax haven under U.S. Internal Revenue Code (IRC) Section 936. Firms in the pharmaceutical industry accounted for approximately 50% of tax credits awarded and 20% of employment under the program. The U.S. Congress eliminated the tax exemption program in 2006, creating a natural experiment on the elimination of corporate taxation of intangible assets. We use panel data on establishments from the Quarterly Census of Employment and Wages and a difference in difference methodology to measure the impact of the elimination of IRC Section 936 on pharmaceutical and medical devices using establishments with low, medium and high participation in the program as controls. Survival rates of all manufacturing establishments declined after the phaseout and elimination of the tax exemption program but pharmaceutical and medical devices establishments experienced an additional 6.9% decline. Approximately 50% of the 34% decline in pharmaceutical and medical devices establishments in Puerto Rico from 1995 to 2017 can be attributed to the elimination of IRC Section 936. Employment in pharmaceutical and medical devices establishments, which also declined by 34%, decreased at the same rate as that of other industries. Plant closings accounted for most of the decline in their employment.