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AMERICAN UNIVERSITY LAW REVIEW
[Vol. 65:1
TABLE OF CONTENTS
Introduction .................................... 22...... I. A Theory of U.S. Tax Imperialism .......................... 12 II. Three Historical Stages of U.S. Tax Imperialism in Puerto Rico... 16 A. Stage One of U.S. Tax Imperialism in Puerto Rico,
1898-1919
B.
....................................
1. U.S. evaluation of Puerto Rico's extant system of taxation ................................... 2. U.S. adjustments to Puerto Rico's extant system of taxation ........................ ......... a. U.S. enforcement of tax laws in Puerto Rico.......... 3. Further U.S. refinements to Puerto Rican tax laws: Property taxation ...................... ...... 4. Further U.S. refinements to Puerto Rican tax laws: Income taxation ................... .......... 5. Assessing the U.S. fiscal restructuring of Puerto Rico ..... Stage Two of U.S. Tax Imperialism in Puerto Rico,
1920-1974
..........................
20 21 25 36 37 42 50
.......... 53
C.
Stage Three of U.S. Tax Imperialism in Puerto Rico, 1975-Present................................. D. Recent Fiscal Developments in Puerto Rico ...... ..... III. A Broader Theory of Tax Imperialism: Possible Future Applications, Points for Further Study................... Conclusion ...............................................
68 78 83 84
INTRODUCTION
Today, Estado Libre Asociado de Puerto Rico (the Commonwealth of Puerto Rico)' is financially and economically distressed; this much
1. See P.R. CONST. art. 1, ยง 2 (establishing a republican form of government for the U.S. territory); see also Act of July 3, 1952, Pub. L. No. 447, 66 Stat. 327 (approving the island's constitution, thereby giving it effect under federal law). Puerto Rico is composed of three separate inhabited islands; however, it is consistently referred to as "the island." See, e.g., CESARJ. AYALA & RAFAEL BERNABE, PUERTO Rico IN THE AMERICAN CENTURY: A HISTORY SINCE 1898 1 (2007) (using the term "the island" to refer to Puerto Rico in a comprehensive account of the island's relations with the United States); see also 48 U.S.C. ยง 731 (2012) (applying "[t]he provisions of this chapter ... to the island of Puerto Rico and to the adjacent islands belonging to the United States and waters of those islands" and declaring that "the name Puerto Rico ... shall be held to include not only the island of that name, but
