On September 29, 2014, the Puerto Rico Treasury issued Tax Policy Circular Letter No. 14-02 (“CL 14-02”) to provide answers to the most frequent questions made by plan sponsors and plan administrators of retirement plans in connection with the pre-payment rules and procedures originally established through Administrative Determination No. 14-16 of August 6, 2014 (“AD 14-16”).  This new guidance overrides and clarifies prior understandings under AD 14-16 with respect to the discretion of the plan administrator or sponsor to recognize pre-payments under the plan.  As such, Puerto Rico employers may be required to take new measures in order to comply with the new pre-payment rules.  Continue reading Puerto Rico Treasury Issues Further Guidance Clarifying the Prepayment Window Rules: Employers May Need to Take Immediate Action to Comply with the Rules on Littler's Puerto Rico Workplace Counsel.