Our team has extensive experience in analyzing the particular business operations of clients in order to optimize their tax strategies and minimize the tax costs of their operations. This practice group is deeply involved in the design, documentation, and implementation of tax and corporate structures for our clients, allowing them to minimize costs, benefit from tax incentives and credits, and confidently expand their operations into other markets. We also have assisted numerous high-net-worth individuals in their personal tax, succession, and asset protection planning.
Our attorneys work collaboratively with our clients’ financial advisors and auditors to ensure that all prospective transactions and deals have the desired legal, tax, financial, and reporting outcome. They also work with our corporate practice group to coordinate the preparation of all documents, contracts and intercompany agreements required to implement or document a particular transaction or tax planning strategy.
We are constantly monitoring new or proposed laws and regulations to determine the potential impact on the tax strategies of our clients. As their business advisors, it is our mission to assist them in developing strategies to ensure compliance with all new tax developments and minimize their impact and cost on their operations.
Most of our tax attorneys are certified public accountants and include attorneys that have previously with the Puerto Rico Treasury Department, participated in drafting the 2011 Puerto Rico Internal Revenue Code and that have actively participated in the legislative process of amendments and reforms through trade and professional associations.
Representative Matters and Transactions
- Represented a U.S.-based private equity fund in the development and implementation of a tax efficient structure for the acquisition of a commercial real estate loan and REO portfolio from a Puerto Rico bank.
- Acted as counsel to a local bank in the design and implementation of procedures for compliance with all federal reporting and withholding requirements under FATCA for its Puerto Rico and U.S. branches.
- Acted as counsel to a multinational pharmaceutical company that had maintained operations within Puerto Rico for approximately 25 years in the process of executing a shutdown its local operations, including the establishment and implementation of a strategy for minimizing the Puerto Rico tax costs/exposures related to the shutdown.
- Advised multinational client in the acquisition of educational institution in New York City in a $6 million transaction that included the forbearance of approximately $12 million 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 or Puerto Rico taxes to client or its shareholders.
- Assisted in the successful establishment on the Island of the two (2) latest biotechnology companies, including the application and obtention of tax exemption grant and negotiation of economic incentives.
- Advised client in the redemption of a majority shareholder stake in a $20 million transaction. Successfully structured the transaction to achieve significant tax and cash flow benefits for the company and its redeemed shareholder.
- In a groundbreaking transaction and first-ever in Puerto Rico, acted as local tax counsel to the purchasers of $350 million of senior secured notes issued for the financing of a world-class P3 transaction involving Puerto Rico’s Luis Muñoz Marín International Airport
