Thursday, September 29, 2016



Japan to tighten taxation rules on overseas dummy companies
Sept 28,2016

The government will tighten taxation rules on dummy companies set up in foreign countries with low corporate tax rates in order to prevent tax avoidance, government sources said.

The new taxation rules call for imposing the nation’s corporate tax rate on dummy corporations overseas regardless of tax rates adopted by local governments, with an eye to adopting the measures in tax system revisions for fiscal 2017, the sources said Tuesday.

The move comes as an increasing number of countries have agreed to adopt tougher international tax rules amid growing public criticism against tax avoidance following the so-called Panama Papers revelations.

Under the current tax system, the government imposes its corporate tax rate, which is currently 29.97 percent, on the combined income of a parent firm and its overseas subsidiaries if they are set up in countries with corporate tax rates of less than 20 percent and deemed dummy companies.

If the subsidiaries are located in such countries as China and Malaysia, which impose corporate tax rates of 20 percent or higher, local corporate tax rules are adopted except on the income from stock dividends, which is subject to Japanese tax.

As for tax revisions for fiscal 2018, the government also plans to oblige financial experts to report to the tax authorities how they advised individuals and firms to avoid taxes and punish them if misconduct is found, the sources said.


Tuesday, September 27, 2016


By Nelson Rodriguez-Lopez 
September 27, 2016

Today, the same private interests who strangled the economy of Puerto Rico for the last forty years went to Washington DC to request from the federal authorities the enactment of a new Section 245A, which will preclude a new form of corporate welfare. And there we go again ! It seems this corporate welfare clause for the Federal Tax Code, is like the eternal Fifth Symphony of Beethoven, never to be finished! 
But what is absolutely obvious is that the same characters of the past comes to life again !
It is clear that the anachronistic Popular Democratic Party of Puerto Rico (PPD), whose "Commonwealth" Status has been consistently declared non personna juridica, (in other words of non existence) by the Supreme Court of the United States of America, is fighting for survival. Maliciously and intentionally, the PPD wants to revive the paradoxically discredited status of Commonwealth as the definition of progress and economical development for Puerto Rico! 

My goodness! $72,000,000,000 billions deficit is not enough! Their pantomime message is that the territorial status is what only safely develops local economy ! With their traditional alliance of privately funded organizations, once more they want to convince Washington DC that a phantom copy of 936 funds will be the only way Puerto Rico will recover again financial stamina! 

That is absolutely false !

Listen carefully! 95% of 936 funds benefits went directly to the huge parents companies of the 936 Corporations !In other words , 95% of the benefits of the 936 funds went to the so-called "corporate welfare "

What a huge mischievous use of funds which were created to rise the level of Puerto Rico 's economy and in some way equalize it to the other state's standards! Are we once again going to repeat the same mistakes of the past forty years? Of course not! Those so called Puerto Rican organizations who went today to Washington DC To lobby and beg for Section 245A are the same facilitators of the huge Great Corporations who took substantially all the benefits of the 936 funds . Congress be aware ! This is the same Blackjack of the past !

1. Where are the National Banks that took the billionaire deposits of Sction 936 funds ? Gone many years ago

2. Where are the foreigners banks that took the billionaire benefits of the 936 funds? Gone, and in these particular deposits, worse ! They were used to create employments in foreign countries as Mexico, Peru , Colombia and Panama! 

3. Where are the foreigners banks that took the billionaire benefits of the 936 funds? They were used for Unlawful activities as money laundering and drug dealings!

Millions and millions of 936 funds were used in the famous Panama Papers by Ramon Fonseca unlawfully created corporate phantom structures !What Puerto Rico needs is not tax exemption for corporate investors, what we need is tax incentives for jobs ! These were the original goals and purposes of Section 936 ! That was the way it was handled during Governor Carlos Romero Barcelo administration ! Those were the same TEFRA Amendments that I personally developed in 1983 ! Jobs , jobs for the people of Puerto Rico! If the investor corporation created local jobs , then they were able to receive tax credits .
But you know it is absolutely deceptive to allow a tax shelter system which automatically will produce tax benefits for companies only by signing a letter of intent for investing ! That is absolutely bizarre! 

$68,000,000,000 billions , that was the Jackpot that produced the ridiculous tax shelter of the 936 Corporations in Puerto Rico in the last forty years ! What a huge loophole for corporate tax predators! 

Congressmen and Senators, do you really want to produce that loophole again ? I do not believe that your constituents will be very happy

But the big tragedy will be that you are not helping effectively the people of Puerto Rico! You will be giving our people the leftovers of the Great Corporations, which will be receiving huge tax benefits for splashing money to their own pocket ! Our fellow Americans Continental Citizens will be paying from their own pockets the benefits that will be using the tax predators !

As part of our people fulfillment we need statehood! But we do not want to be a welfare state ! That is why is so important for us the creation of jobs ! Puerto Rico needs to enter into joined ventures with our fellow Americans citizens , not as beggars , but as proud Americans citizens that workshops efforts, dignity and pride ! Let's all of us finished with territorial colonialism! And that's exactly what represents Section 245A! 

No more dependability on corporate welfare! The 936 funds disappeared from Puerto Rico many years ago, only the $72,000,000,000 billions debt standstill as a monument of territorial-colonialism incompetence fulfilled with local corruption and egotistical "caudillismo " or dictatorship! 

America beware ! Puerto Rico be aware ! Let's not make the same mistake twice ! Because unfortunately there will be no morning after for our 3.5 millions USA citizens living in this blessed Island of Puerto Rico !