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U.S. First Circuit Court of Appeals affirms Puerto Rico corporate alternative minimum tax scheme is unconstitutional

The U.S. Court of Appeals for the First Circuit recently affirmed a U.S. District Court decision that found subsections of Puerto Rico’s Alternative Minimum Tax (AMT) statute unconstitutional. The Court of Appeals affirmed that the District Court had jurisdiction over the case because the taxpayer lacked a plain, speedy, and efficient remedy in Puerto Rico courts due to recent regulatory and legislative changes. Further, the Court of Appeals held that the AMT statute was facially discriminatory and continued the injunction against enforcement of the AMT that had been imposed at the District Court.

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