Krueger v. Secretary of Treasury

Mr. Justice Ramírez Bages

delivered the opinion of the Court.

The question for decision in this case is of vital importance for the economic development program of Puerto Rico in connection with which the Commonwealth Government has provided, as the main incentive for promoting the establishment of manufacturing and hotel enterprises in the country, a tax exemption system which includes the exemption of dividends paid to residents herein by those enterprises enjoying such tax exemptions, provided such dividends accrue from industrial development income.1 Appellee Secretary of *341the Treasury…