The Treasury Department (PRTD) issued Regulation 8444 on the additional tax on gross receipts (ATGR) which is applicable to companies engaged in trade or business within Puerto Rico as part of the AMT computation. According to this Regulation, in order to request a waiver from the ATGR, the taxpayer must show that the ATGR results in undue hardship because the ATGR is a significant amount when compared to the taxpayer's gross profit margin during a 4-year base period (i.e., the 4 years before the tax year in which the waiver request is made). Accordingly, to be eligible for the waiver,...