Puerto Rico is a poor jurisdiction to form and run a captive. My reasons have nothing to do with the law, but with the island's infrastructure, economy, and finances. Let's start with this the islands electric infrastructure:
The blackout in Hurricane Maria's wake was one of the largest ever. More than 160,000 Puerto Rican homes were damaged or destroyed. Power restoration cost more than $3 billion and was mired in controversy: PREPA's seen five CEOs in the 11 months since the storm.
One of those CEOs, former General Electric executive Rafael Díaz Granados, resigned in July, rather than accept demands by the island's Gov. Ricardo Rosselló that his $750,000 salary be reduced. PREPA is bankrupt and $9 billion in debt. In January, Rosselló announced plans to sell the insolvent company.
For months following the hurricane, the Federal Emergency Management Agency helped repair the island's power grid. However, in July FEMA's assistance ended while about 16,000 homes remained without electricity, despite urging from Puerto Rico's Congressional representative for the agency to extend its contract.
Many experts say that despite PREPA's efforts, the island's grid remains as fragile as it was before the storm. Plans to improve it are underway and will cost $26 billion more, according to a report submitted to Congress earlier this month. Days before, a federal judge ruled that the island doesn't have final say over its finances, a decision that has already cut into public assistance.
The first thing to consider when thinking about relocating to a jurisdiction is its physical infrastructure. This is especially relevant in the Caribbean, which is prone to hurricanes. Electricity -- which is something we take for granted in the developed world -- is an issue on the island. Most importantly, the system remains fragile, implying that, should another hurricane hit the island, the electricity problem will occur again. That alone is a reason to look elsewhere.
There are economic issues as well:
The economy has been in a perpetual recession for the last 10 years while the unemployment rate is over 9%. I would argue that high unemployment is structural, meaning it's now built into the economy.
Finally, we have the "Puerto Rico Debt Crisis:"
The Puerto Rican government-debt crisis is a financial crisis affecting the government of Puerto Rico.[a] The crisis traces back its history to 1973 when the government began to spend more than what it collected. To cover that imbalance, the government issued bonds rather than adjust its budget. That practice continued for four decades until 2014 when three major credit agencies downgraded several bonds issues by Puerto Rico to "junk status" after the government was unable to demonstrate that it would be able to pay its debt. The downgrading, in turn, prevented the government from selling more bonds in the open market. Unable to obtain the funding to cover its budget imbalance, the government began using its savings to pay its debt while warning that those savings would eventually exhaust and that it would thus eventually be unable to pay its debt. To prevent such scenario, the United States Congress enacted a law known as PROMESA, which appointed an oversight board with ultimate control over the commonwealth's budget. As the PROMESA board began to exert that control, the government sought to increase revenues and reduce its expenses by increasing taxes while curtailing public services and reducing worker's benefits. Those measures further compounded the crisis by provoking social distrust and unpleasantness in the general population.
The government's finances are about as unsound as you can get.
To sum up: Puerto Rico has
Is this really a place to perform a sophisticated transaction?