In a welcome development for employers working to maintain tax-qualified retirement plans for their employees in Puerto Rico, the Puerto Rico Department of Treasury (the “Hacienda”) last week issued Circular Letter No. 12-09, extending two important deadlines:

  • The deadline for amending plans to comply with the Puerto Rico Internal Revenue Code of 2011 (“2011 PRIRC”) was extended to June 30, 2013, or, if later, the last day of the first plan year beginning on or after January 1, 2012.
  • The deadline for applying for a determination that the plan complies with the 2011 PRIRC was extended to September 30, 2013, or, if later, to the deadline for filing the plan sponsor’s income tax return for the first taxable year commencing on or after December 31, 2011.

Employers who wish to apply for a retroactive determination under the Puerto Rico Internal Revenue Code of 1994 must concurrently apply for a determination under the 2011 PRIRC, and the applications must be submitted together by the applicable deadline. 

The extensions apply to retirement plans that provide benefits solely to employees in Puerto Rico (so-called “Puerto Rico only” plans) and to retirement plans that provide benefits to employees in Puerto Rico and the mainland United States (so-called “dual-qualified plans”).

Tags: Hacienda, Puerto Rico
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Photo of William Woolston William Woolston

Will Woolston helps employers solve tough employee benefits and executive compensation problems. Will is a partner in the firm’s Washington office whose practice focuses on all aspects of global employee benefits and executive compensation for companies of all sizes in a variety of…

Will Woolston helps employers solve tough employee benefits and executive compensation problems. Will is a partner in the firm’s Washington office whose practice focuses on all aspects of global employee benefits and executive compensation for companies of all sizes in a variety of industries, including specialty chemicals and performance materials, disruptive technology, defense and aerospace, gaming and entertainment, and sports.

Will offers a practical approach to employers facing challenging decisions and transactions that impact their officers, executives, employees, and retirees. His approach and perspective developed over many years of close, day-to-day relationships with counsel and staff at major multinationals. In addition, Will provides an insider’s view and appreciation of the challenges facing in-house counsel, having once served as seconded corporate counsel to one of the largest U.S. defense contractors.

Although best described as a generalist in the employee benefits and executive compensation space, Will’s practice focuses significantly on the following areas:

  • Tax-qualified retirement plans, with a particular emphasis on cash balance and pension equity plans
  • Domestic U.S. and global equity incentive programs.
  • Corporate transactions and post-closing workforce integration
  • Executive employment agreements, retention and bonus agreements, and other similar incentives

Will was named a 2020 Law360 Rising Star in Employee Benefits.

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