Critical Manufacturing and Puerto Rico USA

Luis Fortuno and Congresswoman Jennifer Gonzalez

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The panelists :

 

 

 

The ULI Webinar has an incredible array of information crammed into 90 minutes and it gives a great snapshot for the many initiatives being introduced and planned to help the Puerto Rican economy and create more quality jobs. If I had to some it up in three words, Mo is back. Mo of course being momentum.

 Each of the speakers brought a different perspective. Congresswoman Gonzalez Colon noted her primary mission is the reconstruction of the Island and to shephard the many supporting bills recently introduced in the US Congress. Former Governor Luis Fortuno brought an informed Wash DC think tank perspective, Adam Greenfader is one of Puerto Rico´s most passionate advocates, Andy Carlson of JLL (Jones Lang LaSalle) brings experienced commercial  insights from the world´s second largest public brokerage firm, Dr Deusch stated his case for the reasons he brought his Swiss/German manufacturing business to Puerto Rico because of a need for precision and reliability, while Noel Zamot has a finger on the ethical pulse of developing new business in Puerto Rico.

The conversations were upbeat and positive. For instance, Congresswoman Colon made a presentation on MMEDS which was introduced last month to Congress under the bill H.R. 7527. This bill provides tax incentives and tax credits for companies creating manufacturing plants and jobs in economically distressed areas in the US and its territories. The criteria for distressed is even stricter than the recent Opportunity Zone legislation passed in late 2017. When the Congresswoman showed the MMEDS qualifying maps there were smaller areas in very non desirable locations in the US whereas Puerto Rico literally had a much larger proportional area in some desirable locations. And she stated very clearly that MMEDS is one of the very few legislative items that is drawing bi-partisan support from both sides of the aisle.

The entire panel then weighed in on the competitive advantages that Puerto Rico has when competing with the mainland U.S. including much lower labor costs by as much as 60% lower in some cases, an experienced manufacturing labor force going back 100 years, the University of Puerto Rico at Mayaguez which is a top 10% engineering school for the entire U.S. and which is very much geared to provide the engineering and chemistry talent to support Puerto Rico´s manufacturing base. That even today five of the top ten selling drugs internationally are produced in Puerto Rico and 12 of the top 20 pharmaceutical companies have plants in Puerto Rico. Luis Fortuno noted that Puerto Rico had more than $40 billion USD in pharmaceutical exports in 2019 but has the capacity to increase this substantially. The panel noted that some closed down plants are almost in turnkey conditions should manufacturers wish to return or expand capacity. It would not take much. Maybe a recession of the Jones Act, or at least an exemption for an extended period of time, might be the necessary catalyst. There are some interesting new developments on this front as was evidenced last week by Hawaii noting that 85% of their informed populace is all for rescinding the Jones Act as it costs that Island 1.2 billion USD in additional transportation and cost of goods fees.

Progress is being made on seeking some type of exemption under the taxing provisions of GILTI as it adds a 10%+ tax on profits for CFCs (controlled foreign corporations) which unfortunately applies to the US territories since the do not fall under the IRC (Internal Revenue Code). On May 1, 2020, Congresswoman Stacey E. Plasket, representing the US Virgin Islands, filed Bill HR 6648 – the Territorial Economic Recovery Act, that if becomes law, it will exclude our territories from much or all of the GILTI taxation, under certain provisions.

On April 3, 2020, Congresswoman Jennifer González, resident Commissioner for Puerto Rico, introduced Bill HR 6643, the Securing National Supply Chain Act of 2020, to provide various tax credits to Economically Distressed Zones, including a tax credit on the amount of wages paid by an employer to employees in such a zone. The proposal has some overlap with HR 7527 noted above.

President Trump’s Special Representative for Puerto Rico’s Disaster Recovery,  Rear Admiral Peter Brown, lead two delegations to Puerto Rico in August 2020, the last visit being last week. I am told the trip was very successful as a big priority was to visit and understand the many advantages of pharmaceutical manufacturing in Puerto Rico.  AG&T is committed to bringing our network top information and access to our industry’s leaders. 

 

Section 936 and the Case for Reinvesting in Puerto Rico’s Manufacturing Base

Zaida Feliciano Queens College

Section 936 and the Case for Reinvesting in Puerto Rico’s Manufacturing Base

 

The repeal of Section 936 remains one of the most consequential economic policy decisions of the last three decades. It hollowed out Puerto Rico’s manufacturing base, precipitated a fifteen-year economic crisis on the island, and — critically for U.S. supply chain security — pushed critical manufacturing offshore to Mexico, Ireland, Latin America, and China.

Understanding this history is essential to understanding the opportunity Puerto Rico presents to institutional capital today.

What Section 936 Was

Section 936 of the U.S. Internal Revenue Code, enacted in the 1970s, provided federal tax credits to U.S. corporations operating in Puerto Rico. It was designed to encourage industrial investment on the island, and it worked. By the mid-1990s, Puerto Rico had become one of the world’s most concentrated centers of pharmaceutical manufacturing, biomedical devices, and precision industrial production.

The incentive was phased out beginning in 1996 and fully eliminated by 2006.

The Consequences

In their landmark National Bureau of Economic Research paper, “U.S. Multinationals in Puerto Rico and the Repeal of Section 936 Tax Exemption for U.S. Corporations,” economics professor Zadia Feliciano of Queens College and co-author Andrew Green analyzed the effects of the phase-out on Puerto Rico’s manufacturing sector — measuring the impact on establishments, value added, employment, and wages.

Their findings quantified what the island already knew:

  • Manufacturing employment declined sharply
  • Multinational corporations relocated production offshore
  • Wages compressed
  • The island entered what would become a decade-and-a-half of negative economic growth

The consequences extended beyond Puerto Rico. Critical U.S. supply chains — pharmaceutical ingredients, medical devices, protective equipment — moved to foreign jurisdictions where the U.S. government has neither regulatory oversight nor security guarantees.

Why This Matters Now

The Food and Drug Administration has repeatedly expressed concern about U.S. dependence on foreign medical supply chains — particularly on China. Recent geopolitical shifts have accelerated the reshoring conversation across pharmaceutical manufacturing, semiconductors, and defense-critical industries.

Puerto Rico is uniquely positioned to answer that call.

The infrastructure remains in place:

  • 49 FDA-approved pharmaceutical plants currently operating on the island
  • 25% of all U.S. pharmaceutical exports are produced in Puerto Rico — more than any state
  • Cold-chain logistics infrastructure already built out for high-value pharmaceutical exports
  • A workforce experienced in regulated manufacturing — decades of institutional knowledge that cannot be quickly rebuilt elsewhere

For institutional capital thinking about industrial reshoring, Puerto Rico offers something no other jurisdiction can: existing FDA-registered facilities, an experienced labor force, and U.S. jurisdiction — with the potential for renewed federal incentive frameworks.

The Forward Case

The manufacturing tax framework that supported Puerto Rico’s rise has been replaced in part by newer instruments — Act 60, Opportunity Zones, and various targeted incentives. But none has fully restored the strategic advantage Section 936 provided.

For allocators, developers, and policymakers, the question is no longer whether critical manufacturing should return to U.S. soil. That consensus has largely formed. The question is where.

Puerto Rico’s answer: infrastructure is already here, workforce is already trained, regulatory jurisdiction is already U.S.

The learning curve for a company evaluating pharmaceutical production in Puerto Rico is dramatically shorter than for any other U.S. region.

AG&T’s Perspective

At AG&T, we have advised on Caribbean development for nearly three decades — through the pre-936 boom, the post-repeal contraction, the 2017 hurricanes, and the current recovery. We have watched capital allocation cycles play out in real time.

Our conviction is straightforward: Puerto Rico’s manufacturing base is a strategic U.S. asset that has been consistently undervalued. As institutional capital rethinks supply chain resilience, ESG alignment, and long-term industrial strategy, the island’s mature manufacturing ecosystem deserves renewed attention.

The next generation of U.S. industrial policy will be shaped by decisions made in the next five to ten years. Puerto Rico should be central to that conversation.

AG&T is a Caribbean real estate capital advisor founded in 1998. Principal-led, AG&T has been involved in over 55 development projects across Puerto Rico, Sint Maarten, Costa Rica, the Dominican Republic, and other Caribbean markets — connecting institutional capital with regional opportunity. Contact us to discuss Caribbean manufacturing, hospitality, and infrastructure investment.