(a) General rule. — Except as provided in subsection (b), administrative determinations issued by the Secretary pursuant to the provisions of the Puerto Rico Internal Revenue Code of 1994, the Income Tax Act of 1954, the Excise Tax Act of the Commonwealth of Puerto Rico of 1987, the Puerto Rico Estate and Gift Tax Act, or the Alcoholic Beverages Act of Puerto Rico shall not apply in the following cases:(1) The Puerto Rico Internal Revenue Code of 1994. — For taxable years starting after December 31, 2010.(2) The Income Tax Act of 1954. — For taxable years starting after June 30, 1995.(3) The Excise Tax Act of the Commonwealth of Puerto Rico of 1987. — For taxable events taking place after June 30, 1995.(4) The Puerto Rico Estate and Gift Tax Act. — For estates of individuals who die after June 30, 1995, and for gifts made after such date.(5) The Alcoholic Beverages Act of Puerto Rico. — For taxable events taking place on or after the date of effectiveness of Subtitle D of the Puerto Rico Internal Revenue Code of 1994.(b) Special rules. —(1) Administrative determinations under the Puerto Rico Internal Revenue Code of 1994, the Income Tax Act of 1954, the Excise Tax Act of the

rto Rico Internal Revenue Code of 1994.(b) Special rules. —(1) Administrative determinations under the Puerto Rico Internal Revenue Code of 1994, the Income Tax Act of 1954, the Excise Tax Act of the Commonwealth of Puerto Rico of 1987, or the Puerto Rico Estate and Gift Tax Act. — Except when expressly provided otherwise in this Code, an administrative determination issued to a taxpayer based on any provisions of the Puerto Rico Internal Revenue Code of 1994, the Income Tax Act of 1954, the Excise Tax Act of the Commonwealth of Puerto Rico of 1987, or the Puerto Rico Estate and Gift Tax Act, which are identical to the corresponding provisions of this Code and which affect the determination of tax liability for a taxable year starting after December 31, 2010, or June 30, 1995, or a taxable event taking place or property transfer made after December 31, 2010, or June 30, 1995, or to a taxable event or property transfer carried out after December 31, 2010, or June 30, 1995, as applicable, shall be deemed to have been issued under the corresponding provisions of this Code.(2) Administrative determinations in § 30144(b)(6) of this title.

cember 31, 2010, or June 30, 1995, as applicable, shall be deemed to have been issued under the corresponding provisions of this Code.(2) Administrative determinations in § 30144(b)(6) of this title. — Administrative determinations issued by the Secretary in connection with a liquidation as described in paragraph (6) of Section 1112(b) of the Puerto Rico Internal Revenue Code of 1994, which is to be completed within three (3) years from the date of the close of the taxable year during which the first of a series of distributions is made, and said first year, or first two years of such liquidation started before January 1, 2011, shall remain in effect as to taxable years starting after December 31, 2010, which are a part of such three (3)-year term. History —Jan. 31, 2011, No. 1, § 6091.04, retroactive to Jan. 1, 2011.