O ther activities . Qualified manufacturing, service, and other activities are eligible for all of the same benefits. 8 T erm of grant . However, the grantee may elect to start its exemption at anytime during this six-month period, or delay the start for up to two years after the date of commencement of operations is fixed. P roperty taxes, municipal gross receipts .
P arent losses, locally manufactured products .
The renegotiated grant will then provide that these base amounts will continue to be subject to the tax treatment provided in the original grant, until its original expiration date. However, the 1998 TIA does not give any guidance as to how the various special deductions and credits should be allocated between IDI covered by the 1987 TIA and that covered by the 1998 TIA in a renegotiation. T he 1998 TIA also contains a provision identical to one in the 1987 TIA pursuant to which the tax exemption authorities can waive the provisions denying eligibility for an existing business that has previously held an incentive grant, in order to issue a new grant superseding the old one, provided the grantee agrees to make a substantial additional investment in the business or a substantial increase in its employment. C onclusion Puerto Rico is offering better incentives in the 1998 TIA for establishing new manufacturing and service operations than it ever has before. U.S. corporations may obtain the benefit of such incentives for new manufacturing operations in Puerto Rico notwithstanding the phase-down of Section 936, by using subsidiaries incorporated outside the U.S. and investing the profits generated in their business operations in foreign countries rather than repatriating them.