Edwin O. Figueroa-Álvarez provides tax advice to a broad client base that ranges from local to multinational corporations, including Fortune 500 companies, and emerging businesses in many industries, including digital products or mediums, transportation and logistics, technology, e-commerce, energy and renewable energy, retail, hospitality, healthcare, manufacture, and pharmaceutical companies.
With over two decades of experience, Edwin designs tax strategies for reorganizations, M&As, financing, joint ventures, and real estate transactions. He also develops strategies for start-ups and businesses seeking to establish operations in Puerto Rico, including specialized tax incentives and cash grants under Act 60 and others.
Edwin assists clients in obtaining tax incentives grants, including manufacturing and tourism businesses, private equity funds, international financing entities and businesses engaged in export services under the Incentives Code (formerly Act 20-2012) and individuals relocating to Puerto Rico to take advantage of available tax incentives, also under the Incentives Code (formerly Act 22-2012). He has also successfully obtained tax rulings with government agencies and certificates for certain special tax treatments.
He participated in the drafting process of Acts 82 and 83 of July 19, 2010, which created the Puerto Rico renewable energy portfolio standard, and the renewable energy incentives regime, respectively.
He is an experienced tax litigator who has represented many clients in federal and state controversies related to income, municipal license, sales and use, property and construction excise tax deficiency and refund procedures. His litigation experience includes all administrative and judicial aspects, such as tax audits, assessments and examinations through administrative appeals and court proceedings and successful negotiations and settlement of tax disputes with all Puerto Rico taxing authorities.
Edwin is an adjunct professor at Inter-American University Law School teaching tax law in the J.D. program and has served as lecturer at seminars from the Puerto Rico Society of Certified Public Accountants.
Credentials
Bar Admissions
- Commonwealth of Puerto Rico
- United States Tax Court
- U.S. District Court District of Puerto Rico
- U.S. Court of Appeals 1st Circuit
Education
Bachelor's Degree, University of Puerto Rico
- Major: Accounting
- He also passed the Uniform Certified Public Accountant exam
J.D., Interamerican University of Puerto Rico School of Law
LLM, Boston University School of Law
- Major: Taxation
Memberships
Puerto Rico Society of Certified Public Accountants
Representative Transactions
- Member of the team that assisted and represented a major international retailer in a tax constitutional challenge before the federal court on Commerce Clause, Equal Protection, and Federal Relations Act grounds. See Wal-Mart Puerto Rico, Inc. v. Juan C. Zaragoza-Gomez, 174 F. Supp. 3d 585 (DPR 2016).
- Assisted in the tax related matters for the establishment of the largest wind farm in Puerto Rico to date.
- Member of the litigation team that represented taxpayers in tax deficiency litigation proceedings brought by the Puerto Rico Treasury Department, the municipalities, and CRIM.
- Assisted various clients in securing tax refunds owed by the Puerto Rico Treasury Department in light of Puerto Rico’s filing for protection under PROMESA’s Title III bankruptcy proceedings.
- Represented mass media client during administrative and judicial challenge of real property tax assessments on regular and digital advertising outdoor billboards, where the main controversy was a constitutional challenge of the valuation formula used by the taxing authority to impose the tax to the client’s property, as being contrary to the principle of uniformity in taxation.
- Worked with the coordination and design of strategy to promote a tax legislation that had direct impact on multinational retailers operating in Puerto Rico in matters related to sales and use taxes.
- Advised client on the design and structure of Puerto Rico business model for the import, storage, blending and distribution of petroleum and petroleum derivative products in Puerto Rico to maximize tax benefits, including the use of local tax exemption and foreign trade zone benefits.
Honors & Recognition
Edwin is ranked as one of Puerto Rico’s Leading Attorneys in the Tax field by Legal 500 and in the Tax field of The Best Lawyers in Puerto Rico guide.
Community Involvement
Edwin is an active advocate of non-profit organizations, helping them obtain 501(c)(3) exempt status.