International Tax 2026

PUERTO RICO Law and Practice Contributed by: Simón Carlo Valentín, Anthony O. Maceira Zayas and Carlos M. Fontán, Maceira Zayas

Maceira Zayas advises domestic and international clients on tax planning, compliance, corporate, regu - latory and government affairs matters from its prin - cipal office in San Juan. The tax practice focuses on structuring and compliance across Puerto Rico and US federal tax regimes, including matters before the Puerto Rico Department of Treasury (Hacienda) and the Internal Revenue Service. The team counts three dedicated tax attorneys, with two additional corpo - rate practitioners who regularly collaborate on tax- related mandates. The firm advises individuals and

businesses on Puerto Rico’s Act 60-2019 incentive framework, with depth in decree applications, annual compliance, incentive stacking, and the interaction between Puerto Rico and federal tax obligations. Recent engagements include advising the Senate of Puerto Rico on the Governor’s proposed tax reform package, structuring a capital gains position generat - ing approximately USD1.8 million in annual tax sav - ings, and advising a business conglomerate on com - bining multiple Act 60 incentive categories. Carlos M. Fontán serves as special counsel at Maceira Zayas, advising clients on tax incentives, regulatory compliance and business establishment in Puerto Rico. Previously, he served as Director of the Office of Incentives for Businesses within the Department of Economic Development and Commerce, overseeing the implementation of the Puerto Rico Incentives Code (Act 60-2019). His background includes serving as lead attorney at the Puerto Rico Department of Justice in high-profile tax and expropriation cases and as an attorney at the Office of Industrial Tax Exemption. His experience drafting and administering Act 60 provides unmatched institutional knowledge of Puerto Rico’s framework.

Authors

Simón Carlo Valentín leads the tax practice at Maceira Zayas. A licensed attorney, CPA and notary public, he offers a multidisciplinary approach to advising investors and non-profits on corporate structuring, tax incentives

and compliance. His extensive background includes roles at PricewaterhouseCoopers and BDO, serving as Vice President for a major federal contractor, and acting as CFO of a Colombian financial group. This diverse experience provides him with a rare command of both the legal and financial dimensions of complex transactions. He holds a JD, MBA and BSBA in Finance and Accounting from the University of Puerto Rico.

Anthony O. Maceira Zayas is the founding and managing partner of Maceira Zayas, where he serves as external general counsel to domestic and international clients. He guides business strategy and advises on

regulatory affairs, tax incentives and infrastructure before Puerto Rico and federal institutions. With extensive public and private sector experience, he previously served as Executive Director of the Puerto Rico Ports Authority and as Secretary of Public Affairs. In those roles, he led the drafting and passage of landmark legislation, including the Puerto Rico Incentives Code (Act 60-2019). His client base includes Fortune 500 companies across multiple industries.

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