Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.
In light of the State of Emergency declared by Puerto Rico Governor Hon. Wanda Vázquez-Garced, and the closing of most government agencies as a result of Executive Order 2020-023, several employment-related agencies have extended upcoming deadlines. We summarize them below.
Puerto Rico Department of Labor and Human Resources, Memorandum 2020-004
On March 20, 2020, Puerto Rico Department of Labor and Human Resources Secretary Hon. Briseida Torres Reyes issued Memorandum 2020-004, in which she stated that due to the COVID-19 emergency, all deadlines for matters pending before the Department will be extended for a period of 30 days. This extension includes, but is not limited to, matters pending before the Office of Mediation and Adjudication, the Conciliation and Arbitration Bureau, the Arbitration Appeals Office, Anti-Discrimination Unit, as well as the Secretary’s Appeals Office.
The Secretary also extended for 30 days the deadlines to file unemployment, non-occupational disability insurance (SINOT, for its acronym in Spanish) and chauffer’s insurance quarterly returns. The extension also covers payment plans for unemployment, SINOT and chauffer’s insurance.
Puerto Rico State Insurance Fund Corporation
On March 18, 2020, the Administrator of the State Insurance Fund Corporation (SIFC), Jesús M. Rodríguez-Rosa, issued a press release announcing the adoption of additional benefits to employers in light of the COVID-19 outbreak. Foremost, the Administrator announced the extension of all workers’ compensation policies with an expiration date in March until April 30, 2020. Likewise, all government or private contractors are exempt from the compliance of the policy formalization and payment requirements until 10 days after the SIFC resumes its operations completely.
Importantly, although ordinarily employers would have to obtain workers’ compensation coverage for employees working from home, the Administrator stated that current policies would be extended to cover those working remotely until April 30, 2020, or 10 days after the SIFC resumes operations, without having to modify these policies. This is an acknowledgement that the current emergency has required many employers to rely on work-from-home programs in order to continue operations.
Puerto Rico Treasury Department, Administrative Order No. 20-03 and Internal Revenue Circular Letter No. 20-20
On March 13, 2020, Puerto Rico’s Treasury Department issued Administrative Order No. 20-03 (AO) to extend until April 15 the deadline for filing tax returns for “pass-through entities,” as well as the payment of the tax due with this filing and the first installment of the estimated tax. Likewise, the Treasury extended the deadline for the filing of income tax returns until May 15, 2020, as well as any payment due with the filing and the first installment of the estimated tax.
In addition, on March 16, 2020, the Treasury issued Internal Revenue Circular Letter No. 20-20 (CC RI 20-20), providing that all taxpayers who have been economically impacted by the COVID-19 emergency and EO 2020-023, will be subject to a moratorium on their payment obligations under a current payment plan agreement. This moratorium will apply to any payment that had a due date between March 16, 2020 and March 30, 2020.
Puerto Rico State Department, Administrative Order No. 2020-01
Through a press release issued on March 18, 2020, the Secretary of State announced that, in light of EO 2020-023, the deadlines for corporate entities to file their annual reports to the Registry of Corporations, to request the first extension to do so, and to pay their annual fees, were extended until May 15, 2020.
Puerto Rico Supreme Court and United States District Court for the District of Puerto Rico
On March 16, the Puerto Rico Supreme Court issued Resolution EM-2020-03, extending all deadlines originally set for March 16 to April 14, until April 15, 2020. Likewise, the U.S. District Court for the District of Puerto Rico issued General Order Concerning Extension of Deadlines, Misc. No. 20-088, extending all deadlines originally set for March 16 to April 9, until April 10.