The US District Court for the District of Puerto Rico has held that a US corporation is required to reduce the cap on the possessions tax credit under section 936 of the US Internal Revenue Code (IRC) when it transfers a major portion of its businesses to a foreign corporation. Pharmaceuticals, Inc., v. United States, Civil No. 11-1312 (GAG) (10 October 2012). The case involved a US corporation that claimed tax credits for its manufacturing operations based in Puerto Rico under IRC section 936. IRC section 936 allowed qualifying corporations to claim a credit against US income tax for income...