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I think Puerto Rico stands a lot to gain from these changes.

Residents and businesses here file taxes with PR's Hacienda, not the IRS, therefore Section 174 doesn’t affect PR as far as I know. On top of that, PR already has several tax breaks and incentives that may tip the scales even more for some.

It will be a very interesting year though as the head of Hacienda just resigned, so it’s anyone’s guess as to how we’ll end up.

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Actually PR and USVI use the IRS tax code, and for USVI add +10%. There are some local tax breaks in both place for international, non continental us business activity. PR does have some kind of tax break on 'investments' but I don't know if that is only for passive investments, as opposed to your own business. But this is a good suggestion as it is in the USA and is often a great tax deal, with the catch you have to spend less than 180 days per year in the actual states, and spend at least 6 weeks per year in those two US territories. I think you have to spend New Year's Eve there too!

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