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Florida Journal of International Law

Abstract

This Note attempts to answer this question from a taxation perspective, while providing sufficient historical, economic, and contextual analysis to frame the issue properly. Part II focuses on the historical and political circumstances that have intertwined the United States and Puerto Rico, paying particular attention to the taxation issues involved. Part III discusses the Internal Revenue Code section 936 and the story of its demise. Puerto Rico’s aggressive response to the elimination of section 936 is discussed in Part IV, along with the alternatives offered to corporations that are being established in Puerto Rico. Part V concludes with a look at the effect on the Puerto Rican economy and a look toward what the future may hold for the Puerto Rican manufacturing industry.

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