Academic literature on the topic 'Bacardi Corporation (Puerto Rico)'

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 stem canker disease on rambutan (Nephelium lappaceum L.) and litchi (Litchi chinensis Sonn. (Sapindaceae) was found in plants in Hawaii and Puerto Rico. A fungus associated with cankers was identified as Dolabra nepheliae C. Booth & Ting (1). Numerous black, stipitate, elongate ascomata were produced within cracks of cankers. These ascomata contain elongate, bitunicate asci amid unbranched, interthecial elements and thin, cylindrical, hyaline ascospores measuring 96 to 136 × 2.5 to 3.5 μm. This fungus was originally described from Malaysia on N. lappaceum (1) and is also known on pulasan (N. mutabile Blume) in Australia (2). Classified by the Food and Agriculture Organization as a ‘minor disease’, the canker appears to be relatively common in Hawaii and was most likely introduced into Puerto Rico on imported germplasm. Nevertheless, efforts are underway to study the potential damage of this disease as well as mechanisms of control, including introduction of disease resistant clones. Specimens have been deposited at the U.S. National Fungus Collections (Hawaii on Nephelium BPI 878189, Puerto Rico (PR) on Nephelium BPI 878188, and PR on Litchi BPI 878190). Although a specimen of D. nepheliae on L. chinensis was collected from Hawaii in 1984 by G. Wong and C. Hodges and deposited as BPI 626373, this fungus was not known on Nephelium spp. in Hawaii and was not previously known from Puerto Rico on either host. References: (1) C. Booth and W. P. Ting. Trans. Brit. Mycol. Soc. 47:235, 1964. (2) T. K. Lim and Y. Diczbalis. Rambutan. Page 306 in: The New Rural Industries. Online publication. Rural Industries Research and Development Corporation, Australia, 1997.

Abstract Background: In 2014, epidemic chikungunya virus (CHIKV) emerged in Puerto Rico, concurrent with endemic dengue (DENV). The Department of Health mandated blood donation quarantine for 72h pending follow-up donor contact for infectious symptoms. The American Red Cross (ARC) halted local platelet collections and began importing blood components. Imported platelet components (PCs) from the continental U.S. were used to supply hospitals in the Caribbean. An alternative strategy is local PC production with amotosalen +UVA (A-UVA) pathogen reduction (PR) technology (INTERCEPT™ Blood System, Cerus Corporation, Concord, CA) as utilized by the French Transfusion Service in the Overseas Territories, including the Caribbean since 2007. The major logistical advantage of such a strategy is earlier PC availability to hospitals since there is no need to wait for the results of bacterial culture, or transport of PCs from the continental U.S. A-UVA technology inactivates bacteria, viruses, parasites and leukocytes by efficient covalent adduct modification of DNA and RNA, thus addressing risks of bacterial contamination and reducing the risk of transfusion-transmitted infection (TTI). Treatment with A-UVA also prevents transfusion associated graft vs. host disease (TA-GVHD) in an animal model, inhibits clonal T cell proliferation, prevents allogeneic antigen stimulation in mixed lymphocyte reactions, and inhibits transcription mediated cytokine production and early activation antigen expression (Corash et al, BMT 2004) and is recognized by the AABB as a replacement for gamma irradiation in the prevention of TA-GVHD. Aims: A treatment use clinical study (TRUE) was conducted in Puerto Rico under the Investigational Device Exemption (IDE) early/expanded access regulations while the INTERCEPT Premarket approval (PMA) application was under review by the Food and Drug Administration (FDA). The objective of the TRUE study was to provide early access to INTERCEPT to reduce the risk of TTIs during the ongoing CHIKV/DENV epidemic. Methods: A prospective, open label, single arm, treatment use, multi-center study was conducted involving 7 hospitals and the ARC. Apheresis (Trima® or Amicus® collectors) leukocyte-reduced PR PCs, suspended in 100% plasma without gamma irradiation, bacterial contamination testing, or the need for CMV serology were produced. Safety outcome measures included all adverse events (AEs), serious adverse events (SAEs) and acute transfusion reactions. Patients were transfused with study PCs according to local practices for as long as clinically indicated. Results: 90 patients (55.6% male, mean age 67.2 y) were transfused with 256 PR PCs (2.8 ± 3.5/patient). The vast majority of the patients were hematology oncology patients (76.7%). Most patients (81.1%) received 1 transfusion cycle (transfusion support without > 5 days between transfusions) with 2 PR PCs (40.0%), while 32.2% received 1 PR PC, and 25.6% received between 3-10 PR PCs. Mean duration of platelet support was 14.7 days. Thirty-three unrelated AEs were reported in 26 patients. Nineteen patients (21.1%) had unrelated SAEs (including 17 deaths [18.9%]). Two febrile non-hemolytic reactions and one allergic transfusion reaction were reported and deemed unrelated to INTERCEPT by the investigators. No suspected cases of CHIKV or DENV infections or other TTIs were reported. Reported AEs were within the expected spectrum of co-morbidity and mortality for patients of similar age with advanced hematology-oncology diseases. Conclusions: The INTERCEPT Blood System was rapidly deployed in response to the CHIKV and DENV epidemic with replacement of bacterial detection, gamma irradiation and the need for CMV serology. No PR PC related AEs were reported. INTERCEPT was approved in late 2014 by the FDA to treat Amicus apheresis PCs suspended in platelet additive solution and in 2016 for Trima PCs suspended in 100% plasma. The importance of this proactive technology is highlighted by the recent emergence of Zika virus (ZIKV). FDA has recently requested that all blood establishments in Puerto Rico and in certain counties in Florida cease collecting blood immediately until investigational donor screening test for ZIKV RNA is implemented or until they implement the use of an approved or investigational pathogen reduction technology. Disclosures Rico: Cerus Corporation: Employment. Stramer:Cerus Corporation: Other: fee for service study with Cerus Corporation. Benjamin:Cerus corp.: Employment. Cartagena:Cerus Corporation: Other: fee for service study with Cerus Corporation. Arroyo:Cerus Corporation: Other: fee for service study with Cerus Corporation. Robles:Cerus Corporation: Other: fee for service study with Cerus Corporation. Carlo:Cerus Corporation: Other: fee for service study with Cerus Corporation. Vera:Cerus Corporation: Other: fee for service study with Cerus Corporation. Solivan-Ortiz:Cerus Corporation: Other: fee for service study with Cerus Corporation. Huang:Cerus Corporation: Employment. Koontz:Cerus Corporation: Employment. Berry:Cerus Corporation: Employment. Corash:Cerus Corporation: Employment.

The San Juan Bay Estuary Program and the Corporation for the Conservation of the San Juan Bay Estuary, intends to develop a cost-effective and environmentally acceptable plan for water quality improvement and seagrass restoration in the Condado Lagoon. One of the principal challenges associated with this Project is evaluating options for dredge material sources (borrow sites), transport, and placement in the Condado Lagoon to achieve the ecological restoration goal. A potential borrow site has been identified in the northwestern side of San Juan Bay near La Esperanza Peninsula. The accretion of sediment near the Peninsula has inhibited tidal flushing to this area from San Juan Bay. The implementation of this Project would support the beneficial use initiative by dredging the shoaling material at La Esperanza Peninsula and filling the artificial depressions in Condado Lagoon to improve water circulation at both the dredge and fill sites; as well as providing habitat for epibenthic growth in the Lagoon. In March 2011, Tetra Tech performed baseline investigations in Condado Lagoon, Puerto Rico in support of the San Juan Bay Estuary Program’s Water Quality Improvement and Seagrass Restoration Project. Field investigations included a bathymetric (multibeam) survey, benthic community data collection and sediment sampling. The results of the surveys were used to characterize benthic habitats in the Lagoon and to assist in evaluating alternatives for restoring the Lagoon to a gradient that supports a diverse epibenthic assemblage of Lagoon and estuarine species, specifically seagrass communities. In addition to the above mentioned investigations, Caribbean Oceanography Group deployed GPS-tracked lagrangian drifters in the lagoon in order to gather current data for the calibration of a hydrodynamic model of the Condado Lagoon. The intent of the multibeam survey was to map the existing depths and bathymetric features within Condado Lagoon, with an emphasis on detailing the extents of seven artificial depressions. The results of the survey determined a minimum depth of 0.8 m and maximum depth of 10.4 m (2.6 to 34.1 ft) in the Lagoon. Maximum depths were recorded in the center of the dredge holes, which are located in the center and eastern end of the Lagoon. The results of the multibeam survey were also used to support depth-based in situ data collection of the benthic community. The results of the benthic survey indicate a regional separation in benthic community diversity and abundance. The south-central and southeastern sides of the Lagoon support low to no biotic cover. This is contrary to the biotic diversity and abundance at the western, north-central and northeastern sides of the Lagoon. The benthic data also showed a segregation of benthic community assemblages between three depth ranges (shallow 1.8 to 2.4 m [6.0 to 8.0 ft]; mid (2.7 to 5.8 m [9 to 19 ft]); and deep 6.1 to 9.1 m [20 to 30 ft]). The benthic community in the mid depth range supports the greatest diversity and abundance of organisms. The areas with little to no biotic cover correspond to the dredged areas of the Condado Lagoon. Typical of low energy environments, finer grained sediments are located in the central and eastern regions of the Lagoon. Grain size analyses reported coarse material at the La Esperanza Peninsula sample site and the western end of Condado Lagoon, which are indicative of currents and regular water exchange in these locations. Organic content decreases from west to east in the Lagoon which supports the observations of lower benthic cover in the south-central and southeastern Lagoon compared to the western region. Based on the 2011 baseline investigations, H. decipiens was determined to be the most prevalent seagrass species in the Lagoon, followed by T. testudinum. Fill volume calculations based solely on the bathymetric survey results, estimate between 132,211 and 488,719 cy of fill material needed to support a water depth gradient (2.7 to 5.8 m [9.0 to 19.0 ft]) conducive to H. decipiens and T. testudinum growth in the central and eastern portions of the Lagoon. More specifically, the baseline results suggest a preferred depth of 4.05 m (13.3 ft) for H. decipiens, which would require between approximately 317,629 and 336,504 cy of fill material to restore a portion of the Lagoon. Caribbean Oceanography Group (with the support of Tetra Tech) has modeled the circulation within the Lagoon using the Environmental Fluid Dynamics Code (EFDC) hydrodynamic model. Modeling results reveal a complex circulation within the Condado Lagoon that is largely wind driven. A statistical analysis of the wind record for NOAA’s U.S. Coast Guard Station ID 9755371, located at the western end of the model domain was carried out, and 70%, 80%, 90%, 95% and 98% exceedance levels were determined. Model results show that under the 98% wind speed exceedance scenario, two of the examined locations within the dredged area of the lagoon experience a shear stress large enough to trigger a minimum sand grain diameter requirement for stability through the Shields relation. The locations and their minimum sand grain diameters are: A-2 with 0.46 mm and A-3 with 0.21 mm. These grain sizes correspond to Medium Sand and Fine Sand, respectively (after Wentworth (1922)). Evaluation of the direction of the shear at the above mentioned locations reveals that a portion of the material eroded from location A-2 (the medium sand) will be deposited at location A-3, and the rest (the fine sand) will be deposited at some combination of locations A-4, A-5, A-6 and A-7. Likewise the material originally eroded from location A-3 (fine sand) will be deposited at some combination of locations A-4, A-5, A-6 and A-7. Therefore, any unstable material placed at locations A-2 and A-3 will merely be shifted to another location within the fill area with a lower shear stress where it will become stable. Therefore the requirements for fill stability in the Condado Lagoon in terms of grain size are: 1) In order to remain stable under a 98% exceedance wind event, fill at location A-2 should be composed of sand with a grain diameter greater than 0.46 mm. In other words, Medium to Coarse sand should be used to fill location A-2. 2) In order to remain stable under a 98% exceedance wind event, fill at location A-3 should be composed of sand with a grain diameter greater than 0.21 mm. In other words, Fine to Medium sand should be used to fill location A-3. Of note is the finding that any material too fine to remain stable at either A-2 or A-3 will be deposited at some combination of the remaining fill locations, and thus will not be lost from the fill area, nor will it be unstable and cause problems elsewhere in the lagoon. It should be kept in mind that the lower exceedance levels (95% or less) did not present any minimum sand grain size requirements for stability. For those cases, sand fill of any grain size remains stable. Likewise, a higher exceedance level than 98% would require coarser fill at A-2 and A-3 than that discussed above. In either case, however, the eroded material would remain within the fill area, being deposited the downstream at a more sheltered location

This chapter presents a case study that investigates the pricing of key contract provisions in Puerto Rican debt. It contributes to a body of research that asks whether investors price contract provisions and, if so, whether the pricing varies with credit risk. Contract provisions across different types of Puerto Rican bonds contain multiple sources of variation. Specifically, the chapter examines investor pricing of three key legal provisions of Puerto Rican debt; general obligation debt versus the secured bonds issued by the Puerto Rico Sales Tax Financing Corporation; debt issued under New York law versus Puerto Rican law; and finally impact of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA) which retroactively enacted collective action clauses for Puerto Rican debt. In each instance, we find evidence consistent with the hypothesis that investors value specific contract provisions and legal protections and more so when credit risk is high, and restructuring becomes likely.