Medchem (P.R.), Inc. - Page 40




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          for a more efficient system exempting possessions corporations so           
          that the possessions would not lose a significant source of                 
          capital.  See Coca-Cola Co. & Subs. v. Commissioner, supra at 22.           
          In place of the exemption mechanism contained in section 931,               
          Congress enacted section 936 to permit a U.S. corporation to                
          elect a tax credit to offset the U.S. tax on its possessions                
          income.  Thus, the current version of the investment incentive              
          takes the form of a tax credit rather than an exemption.                    
               It is clear from the legislative record that Congress was              
          aware of the highly favorable tax benefits afforded U.S.                    
          corporations operating in Puerto Rico.  It is equally clear that            
          Congress intended to retain and reaffirm such tax benefits by               
          enacting section 936.  The Senate Finance Committee and the House           
          Ways and Means Committee stated the following, in virtually                 
          identical reports:                                                          
                    The special exemption provided (under sec. 931) in                
               conjunction with investment incentive programs                         
               established by possessions of the United States,                       
               especially the Commonwealth of Puerto Rico, have been                  
               used as an inducement to U.S. corporate investment in                  
               active trades and businesses in Puerto Rico and the                    
               possessions.  Under these investment programs little or                
               no tax is paid to the possessions for a period as long                 
               as 10 to 15 years and no tax is paid to the United                     
               States as long as no dividends are paid to the parent                  
               corporation.                                                           
                    Because no current U.S. tax is imposed on the                     
               earnings if they are not repatriated, the amount of                    
               income which accumulates over the years from these                     
               business activities can be substantial.  The amounts                   
               which may be allowed to accumulate are often beyond                    
               what can be profitably invested within the possession                  





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