Here the two have a linkage. Certain foreigners become liable for certain taxes 12 months after being granted temporary residency by Migraciones. That much is reasonably clear. What is unclear is whether AFIP would construe someone who has held a precaria for 12 months as having held a temporary residency for 12 months and thus becoming taxable at that point. It would of course have to be tested, and may never have been. Your interpretation of the migration law as it existed under Macri would seem to give some advantage to the foreigner on a long-term precaria who did want to be taxable in the years the law was in place (but less advantage now that the law has changed).