HR364 proposes reducing the physical presence test for U.S. territorial tax exclusion from 183 to 122 days. This bill is in early stages (referred to Ways and Means). No spending authorization. Impact is speculative and low-conviction for most mainland companies. Pure-play territorial banks like OFG are most structurally exposed, with secondary beneficiaries being manufacturing and consumer companies with Puerto Rico operations.
→ A broader base of skilled talent (engineers, managers) can qualify for territorial tax exclusion, reducing Edwards' effective compensation costs for personnel relocated to PR and supporting manufacturing stability.
HR364