Puerto Rico: The Evolution of America's Corporate Tax Haven

2014 ◽  
Vol 12 (1) ◽  
pp. 17-40 ◽  
Author(s):  
Thomas D. Schultz ◽  
Kyle Scott
Keyword(s):  
Puerto Rico ◽  
Intellectual Property Rights ◽  
The United States ◽  
Corporate Tax ◽  
Sales Revenue ◽  
Microsoft Corporation ◽  
Tax Haven ◽  
Federal Taxation ◽  
Tax Benefits ◽  
Foreign Corporations

ABSTRACT We examine the taxation of corporate income earned in the Commonwealth of Puerto Rico and how the repeal of the possession tax credit available under Internal Revenue Code (IRC) §936 resulted in many U.S. companies converting former possessions corporations into controlled foreign corporations. Although Puerto Rico is a U.S. territory, the conversions highlight that corporations organized under the laws of the Commonwealth generally are foreign corporations for U.S. tax purposes. A U.S. Senate Subcommittee reports Microsoft Corporation shifted offshore the recognition of nearly one-half of its U.S. net retail sales revenue for the period 2009–2011 by transferring intellectual property rights to a controlled subsidiary in Puerto Rico. We find that the corresponding U.S. tax benefits are significant compared to the credits once claimed under IRC §936, and over 20 percent of Standard & Poor's (S&P) 500 firms were in a similar position to avoid federal taxation by shifting income between political subdivisions of the United States.

A Comparative Study of Pharmaceutical Incentives to Patents in India, USA and Europe

2020 ◽  
Vol 07 ◽  
Author(s):  
Renu Kadian ◽  
Arun Nanda
Keyword(s):  
United States ◽  
European Union ◽  
Intellectual Property Rights ◽  
United States Of America ◽  
Financial Support ◽  
Development Process ◽  
The United States ◽  
Drug Development Process ◽  
Data Exclusivity ◽  
Patent Term

Background:: Protection of Intellectual Property Rights is a clear incentive to innovations; yet, several countries have provided further incentives to patents in pharmaceuticals because the full patent term of 20 years is largely exhausted, before marketing authorization. Objective:: The purpose of this article is to describe the various incentives to patents in the form of financial support, data exclusivity and most importantly extended market exclusivities and comparison of various incentives to patents in the United States of America, European Union and India. Methodology:: The detail of incentives is collected from various articles, latest topics, books, and newspapers. Result:: These incentives create a positive surrounding to encourage the drug development process, strengthen economic growth and improve a balance between new pharmaceuticals in the market and access of that medicine to general public at a reasonable price. Conclusion:: European Union and the United States of America are leading in the field of incentives to patenting in phar-maceuticals as compared to India. Indian Patent Act, 1970, needs to be re-looked in terms of data exclusivity and patent term extensions.

Explosions

2018 ◽  
Author(s):  
E. Douglas Bomberger
Keyword(s):  
United States ◽  
New York ◽  
Puerto Rico ◽  
The United States ◽  
Woodrow Wilson ◽  
One Step ◽  
Do So ◽  
Laws And Regulations

On 2 April 1917, President Woodrow Wilson urged Congress to enter the European war, and Congress voted to do so on Friday, 6 April. On the 15th of that month, Victor released the Original Dixieland Jazz Band’s record of “Livery Stable Blues” and “Dixieland Jass Band One-Step”; it caused an immediate nationwide sensation. James Reese Europe travelled to Puerto Rico in search of woodwind players for the Fifteenth New York Regiment Band, and the Creole Band ended its vaudeville career when it missed the train to Portland, Maine. German musicians in the United States came under increased scrutiny in the weeks after the declaration of war, as the country prepared to adopt new laws and regulations for wartime.

Protecting User Interfaces

2017 ◽  
Author(s):  
Noam Shemtov
Keyword(s):  
Intellectual Property ◽  
Property Rights ◽  
Intellectual Property Rights ◽  
User Interfaces ◽  
Patent Protection ◽  
The United States ◽  
Graphical User Interfaces ◽  
Unfair Competition ◽  
European Patent ◽  
Intellectual Property Rights Protection

This chapter examines the scope of protection to which graphical user interfaces may be eligible under various intellectual property rights: namely, trade marks, unfair-competition laws, design rights, copyright, and patents. It first considers the extent of copyright protection over a software product’s ‘look-and-feel’ elements, with particular emphasis on graphical user interfaces protection under US and EU laws. It then discusses trade-mark, trade-dress, and unfair-competition protection for graphical user interfaces, along with intellectual property rights protection for design patents and registered designs. Finally, it describes the patent protection for graphical user interfaces in the United States and at the European Patent Office.

scholarly journals Transmission Potential of Zika Virus by Aedes aegypti (Diptera: Culicidae) and Ae. mediovittatus (Diptera: Culicidae) Populations From Puerto Rico

2021 ◽  
Author(s):  
Rebecca A Zimler ◽  
Donald A Yee ◽  
Barry W Alto
Keyword(s):  
Puerto Rico ◽  
Aedes Aegypti ◽  
Zika Virus ◽  
Mosquito Species ◽  
The United States ◽  
Infection Rates ◽  
Transmission Potential ◽  
Transmission Rates ◽  
Higher Doses ◽  
Local Transmission

Abstract Recurrence of local transmission of Zika virus in Puerto Rico is a major public health risk to the United States, where mosquitoes Aedes aegypti (Linnaeus) and Aedes mediovittatus (Coquillett) are abundant. To determine the extent to which Ae. mediovittatus are capable of transmitting Zika virus and the influence of viremia, we evaluated infection and transmission in Ae. mediovittatus and Ae. aegypti from Puerto Rico using serial dilutions of infectious blood. Higher doses of infectious blood resulted in greater infection rates in both mosquitoes. Aedes aegypti females were up to twice as susceptible to infection than Ae. mediovittatus, indicating a more effective midgut infection barrier in the latter mosquito species. Aedes aegypti exhibited higher disseminated infection (40–95%) than Ae. mediovittatus (<5%), suggesting a substantial midgut escape barrier in Ae. mediovittatus. For Ae. aegypti, transmission rates were low over a range of doses of Zika virus ingested, suggesting substantial salivary gland barriers.

The Myth of the Latin American Race Monolith: Notes for Future Comparative Research on Racial Inequality in the Americas

2021 ◽  
pp. 003464462199600
Author(s):  
Diego Ayala-McCormick
Keyword(s):  
United States ◽  
Puerto Rico ◽  
Latin American ◽  
Comparative Research ◽  
Racial Inequality ◽  
Census Data ◽  
The United States ◽  
Unemployment Rates ◽  
Racial Ideologies ◽  
Racial Lines

It has become common to compare racial inequality in the United States with a “Latin American” pattern of racial inequality in which egalitarian racial ideologies mask stark socioeconomic inequalities along racial lines. However, relatively few comparative studies exist attempting to analyze variations in degrees of racial inequality in the Americas. To stimulate further research in this area, the following study analyzes census data on racial inequality in unemployment rates, educational attainment, homeownership rates, and income in Brazil, Colombia, Cuba, Puerto Rico, and the United States. The results suggest that while Brazil is similar to the United States in displaying large levels of racial inequality in the areas measured, Cuba and Puerto Rico display significantly lower levels of racial inequality and Colombia falls in between, undermining conceptions of a monolithic Latin American racial system.

A BIOSYSTEMATIC REVISION OF THE GENUS MUSCIDIFURAX (HYMENOPTERA: PTEROMALIDAE) WITH DESCRIPTIONS OF FOUR NEW SPECIES

1970 ◽  
Vol 102 (10) ◽  
pp. 1268-1290 ◽  
Author(s):  
Marcos Kogan ◽  
E. F. Legner
Keyword(s):  
United States ◽  
Puerto Rico ◽  
Central America ◽  
New World ◽  
The United States ◽  
Additional Species ◽  
Local Populations ◽  
Morphological Studies ◽  
Scanning Electronmicroscopy ◽  
United States Mexico

AbstractExtensive collections of synanthropic fly parasitoids in animal excrement accumulations in the United States, Mexico, Costa Rica, Puerto Rico, Uruguay, Chile, Denmark, Israel, and South Africa yielded seven forms of a Muscidifurax complex which were totally or partially reproductively isolated. Morphological studies of female and male parasitoids coupled with biological and zoogeographical information permitted the identification of five sibling species. Muscidifurax raptor Girault and Sanders 1910 is redescribed and four additional species are described as new: M. zaraptor, from the southwestern United States; M. raptoroides from Central America and Mexico; M. uniraptor from Puerto Rico, and M. raptorellus from Uruguay and Chile. Biological notes are added to the descriptions, and it was postulated that the genus is undergoing a process of speciation with local populations slowly becoming reproductively isolated and eventually giving rise to morphologically distinguishable entities. Most evidence suggests the establishment of Muscidifurax in the New World, concomitant with or shortly following the establishment of muscoid flies in accumulated excrement. Scanning electronmicroscopy was used in the analysis of some morphological structures.

Technische Universitaät Darmstadt v. Eugen Ulmer KG

2015 ◽  
Vol 109 (1) ◽  
pp. 161-167
Author(s):  
Anne-Marie Carstens
Keyword(s):  
Intellectual Property Rights ◽  
Public Interest ◽  
The United States ◽  
Fair Use ◽  
The European Union ◽  
The Public ◽  
Court Of Justice ◽  
International Attention ◽  
International Obligations ◽  
Mass Digitization

In Technische Universität Darmstadt v. Eugen Ulmer KG, the Court of Justice of the European Union (ECJ or Court) addressed several important copyright issues stemming from a practice that continues to confound many legal practitioners and adjudicators: the mass digitization of library collections. The judgment adds to an emerging body of jurisprudence decided in the context of a trend toward greater digitization that could ultimately facilitate the development of a global, digital library. To date, the jurisprudence has largely been formed by cases challenging mass digitization that are percolating through the United States courts and have attracted international attention and criticism. The ECJ decision thus provides an important point of reference for evaluating how different jurisdictions balance the rights of authors against the public interest, as served by relevant fair use exceptions consistent with their international obligations under traditional copyright treaties, the 1996 WIPO Copyright Treaty, and the 1994 Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPs) applicable to all WTO member states.

Lived experiences of Puerto Rican university students displaced to South Florida after Hurricane Maria

2021 ◽  
Vol 0 (0) ◽  
Author(s):  
Tunde Szecsi ◽  
Hasan Aydin ◽  
Debra Giambo
Keyword(s):  
Puerto Rico ◽  
University Students ◽  
The United States ◽  
South Florida ◽  
Education Administration ◽  
Emotional Needs ◽  
Structured Interviews ◽  
Social Emotional ◽  
Community Agencies ◽  
Qualitative Phenomenology

Abstract The purpose of this study is to document the experiences, services, and programs provided to displaced university students from Puerto Rico and to offer recommendations to educational and community agencies regarding effective integration after a natural disaster. Through in-depth semi-structured interviews, this qualitative phenomenology study consisted of collecting oral histories of six displaced university students from Puerto Rico who relocated to Southwest Florida after Hurricane Maria. The analysis of the data indicated three themes, including (1) trauma after hurricane, (2) challenges and needs during relocation, and (3) conflicting feelings about the homeland and the United States. Although immediate, basic needs were met soon after relocation, in-depth, social-emotional needs, such as dealing with trauma and becoming acculturated in the new culture, remained unanswered. Recommendations are provided to higher education administration, professionals in education, and community agencies.

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