Get to know Pedro
Pedro P. Notario-Toll is a Capital Member as well as the founder of Ferraiuoli’s Tax Law Practice Group. A tax advisor since 1991, Pedro has spent his career developing and implementing sophisticated tax planning strategies for his individual and business clients in order to reduce their tax liabilities.
From the time he began practicing to this day, Pedro has been actively involved in:
- devising sophisticated tax and corporate structures for clients who are expanding operations locally and making outbound investments from Puerto Rico
- structuring the inbound Puerto Rico investments and operations of multinational entities
- providing advice regarding the tax aspects of contracts, mergers, acquisitions and reorganizations
- coordinating and preparing documentation to minimize and avoid tax exposure
- negotiating rulings and closing agreements with the Puerto Rico tax authorities
- representing clients in administrative processes related to tax law
- securing approvals and monetization of Tax Credits
- negotiating tax exemption grants under the multiple Puerto Rico Tax incentive laws, including Green Energy Incentives, Film Incentives, Industrial Incentives, and Export Incentives.
- advising the Government of Puerto Rico on Tax Legislation and Regulations
Prior to joining Ferraiuoli, Pedro was a Senior Tax Manager with Arthur Andersen LLP as well as head of his own tax consulting company where he provided tax services to high net worth individuals and expatriates, privately owned partnerships and corporations, and Fortune 500 companies. He also has extensive public sector experience having served as Special Advisor for Internal Revenue Matters to the Puerto Rico Secretary of the Treasury (1996) and the Treasurer of the Puerto Rico Industrial Development Company (PRIDCO) (1997–98).
Why Ferraiuoli?
Although Ferraiuoli has only been in existence since 2003, from the very beginning the firm has made it a priority to empower people and allow them to grow professionally by providing them with the necessary resources and support to reach their potential. While we have grown rapidly, we still maintain that small firm accessibility so that everyone, clients and our professionals alike, can feel comfortable interacting with our practice leaders.
We take a holistic approach to our work. This means that every case and transaction that we work on is informed not only by our knowledge of the law, but also by our understanding of the real life business concerns of our clients.
Why do your clients come to you?
Most of the attorneys in my practice area are not only great lawyers, but also Certified Public Accountants. We think in numbers and language. We provide sophisticated analysis of the tax laws and the legal consequences for our clients because we know their business and are true business advisors to them. Here in Puerto Rico, the tax laws are always changing. By knowing my clients’ business, I can give advice on proposed and enacted laws and explain the impact on their specific business and industry as well as assist them in becoming active participants in the legislative and regulatory process.
The firm has substantial government relationships at all levels and has a strong reputation as a result of our principles and excellent work product. I am fortunate to have the respect of government officials who value my opinion and integrity which helps to get favorable results for my clients.
Looking forward, what you see?
Puerto Rico is actively encouraging foreign and domestic US investment here on the Island. Many of these programs have been around for decades while other programs such as Act 20 and Act 22, though recently enacted, borrow language from other programs to provide certainty as to their validity and legal interpretation by the courts.
In order to successfully navigate this ever changing landscape, it is crucial that businesses and individuals have the benefit of experienced tax professionals who can help them develop business models that will result in desired outcomes.
- Advised Highstar Capital on the structuring of a $350MM credit facility related to the privatization of Luis Muñoz Marin International Airport.
- Advised a major multinational financial institution in the implementation of FATCA procedures for its Puerto Rico operations.
- Successfully negotiated and obtained government approval for millions of dollars in film tax credits, including groundbreaking transactions that allocated film incentives under Act #27 to television programs, live recording projects and live streaming projects.
- Represented a multinational pharmaceutical company regarding the tax consequences of a shutdown of its Puerto Rico operations, and the negotiation of Closing Agreements with multiple tax authorities to settle and minimize the tax costs/exposures related to the shutdown.
- Advised multinational client in the acquisition of a New York based school in a $6MM transaction that included the forbearance of approximately $12MM of target debt. Negotiated all tax and financial clauses related to the acquisition and forbearance documents and structured the transaction and related documents in order to avoid the imposition of federal, New York or Puerto Rico taxes to client or its shareholders.
- Assisted a client in the total redemption of the majority shareholder in a $17MM transaction. Designed and implemented a transaction structure that achieved significant tax and cash flow benefits for the company and its redeemed shareholder.
- Advised a local client engaged in the education technology business in the worldwide expansion of its operations, including (1) design and implementation of efficient tax structure for joint venture with stateside investors to finance the worldwide expansion; (2) performance of tax due diligence in connection to transaction; (3) negotiation of tax clauses on all company agreements related to expansion; and (4) execution of multiple closing agreements to clarify multiple pre-closing uncertain tax positions with the Puerto Rico Treasury Department.
- Panelist at Open Microphone Question and Answer Session, 2015 Puerto Rico Investment Summit – Act 20 & 22
- Speaker, Private Sector Perspective – Effects of Tax Reform in Manufacturing and Services Industries, 2015 Puerto Rico Manufacturer’s Association Competitiveness Forum
- Speaker on Puerto Rico Film Credits & Incentives, 2013 American Film Market, Los Angeles, California
- Speaker on Proposed Puerto Rico Tax Reform, 19th Annual Puerto Rico Association for Financial Professionals Convention
- “International Comparative Legal Guide to Corporate Tax 2015 (Puerto Rico),” with Reinaldo Diaz-Perez, published by Global Legal Group Ltd., London.
Education
- Interamerican University School of Law, J.D., summa cum laude, 2008
- University of Pennsylvania, Wharton School of Business, B.S. in Accounting with honors, 1991
Bar Admissions
- Commonwealth of Puerto Rico
- State of Florida
Affiliations
- Puerto Rico Certified Public Accountants Association
Professional Recognition
- Pedro has been recognized in the 2015 Latin American Edition of Chambers & Partners as an “experienced and adept practitioner in this space.”
