Labor Watch



If you have any questions in regards to the above, please do not hesitate to contact our offices so that we may explain the amendments to the provisions of the Code in more detail. Our address is:


Fiddler González & Rodríguez, P.S.C., P.O. Box 363507, San Juan, PR 00936-3507. Our fax (787) 759-3108.


We welcome your questions and comments.

José J. Santiago



Carlos A. Padilla



Antonio L. García



Edgardo Barreto







On May 28, 2013, the Treasury Department issued Circular Letter 13-02 informing a second extension of the period for adopting required amendments to qualified retirement plans and to file a request for a determination letter until April 15, 2014. This extension benefits employers who are up against the clock with regards to the previous deadline of June 30, 2013 to internally approve the required amendments in their pension plans.


Many private employers offer retirement plans to their employees and the majority of these plans are qualified under the Puerto Rico Tax Code. The Puerto Rico Internal Revenue Code was amended in January 2011, adopting new rules and requisites applicable to the qualified retirement plans. Under the new Code, employers generally had until December 31, 2012 to internally approve the changes to the plans and until April 15, 2013 (July 15, 2013 with an extension of time) to request a determination letter for the plan from the Treasury Department.


In November of 2012, Circular Letter 12-09 was issued extending the period to internally approve the required amendments in their pension plans until June 30, 2013 and to request a determination letter for the plans from the Treasury Department until September 30, 2013.


On May 28, 2013, a second extension was issued by Circular Letter 13-02 allowing until April 15, 2014 to internally approve the required amendments in their pension plans as well as to request a determination letter for the plans from the Treasury Department. The April 15, 2014 due date applicable to request a determination letter from the Treasury Department may be extended further until July 15, 2014 upon paying an additional fee of $150.


Please note that these deadlines are for employers whose tax year is based on a calendar year (January to December). If the employer or the plan’s tax year is different from a calendar year, the dates are different.


The Labor Law Group at Fiddler González & Rodríguez, P.S.C., will issue the FGR LABOR WATCH with information of legal issues and developments in areas of interest to our friends and clients. If you know anyone who would like to receive the FGR LABOR WATCH, please feel free to forward this newsletter. For more information about any matter raised in this Labor Watch, please contact your usual FGR labor lawyer or José A. Silva Cofresí at

©2014 FIDDLER GONZÁLEZ & RODRÍGUEZ, P.S.C. Permission is granted to view, store, print, copy or distribute the content of this newsletter for noncommercial or personal use, provided you do not alter it and you give us proper credit. The content of this newsletter is for informational purposes only. It is not legal advice or advertising. In addition, the above discussion has been provided in general terms and, therefore, should not be relied upon as legal advice applicable to a specific set of facts and circumstances. Before taking legal action, consult a lawyer you trust. Although we will try to be accurate, you cannot rely on its applicability to your specific problem without consulting your lawyer. Fiddler González & Rodríguez, P.S.C. and the members of the Labor Law Group assume no responsibility to inform you of additional changes in law or any other legal issues related to matters addressed in this email of which we may become aware after the date hereof. This newsletter is not intended to create an attorney-client relationship between you and our firm or any of our attorneys. If we are not already representing you, be mindful that your email communications to any of our lawyers will not be treated as privileged or confidential until you ask us to represent you, we first conduct a conflict of interest search, we agree to represent you and you sign an engagement letter from the law firm.

***IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any United States federal tax advice in this communication (including any attachments) is not intended or written by Fiddler González & Rodríguez, P.S.C. to be used, and cannot be used, for the purpose of (i) avoiding any penalties under the Internal Revenue Code, or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. **



Office Location:

254 Muñoz Rivera Ave. 6th Floor

Hato Rey, Puerto Rico 00918


Mailing Address:

PO Box 363507

San Juan, PR 00936-3507


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