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SyCipLaw’s Tax Department has prepared a double edition of its Tax Issues and Practical Solutions (T.I.P.S.) for January-February.

The SyCipLaw T.I.P.S for January-February 2025 covers the following tax issues:

  1. In a claim for refund of excess and unutilized creditable withholding tax (“CWT“), is the requisite of showing on the recipient’s return that the income received was declared as part of the gross income met by the mere fact that the income from which CWT is withheld is less than the total income reported by the taxpayer-claimant in its income tax return? 
  2. May a taxpayer claim a refund of input valued-added tax (“VAT“) attributable to zero-rated sales under Section 112 of the Tax Code when the taxpayer’s purchases were zero-rated?
  3. Are foreign currency deposits in the Philippines subject to estate tax?
  4. In a case involving misdeclaration of goods, how may a consignee overcome the prima facie evidence of fraud to redeem goods that have been seized by the Commissioner of Customs?
  5. Is the list of officers to whom a valid assessment protest may be filed under Revenue Memorandum Circular No. 039-13 an exclusive list?
  6. Is a mail clerk, who is authorized to receive general mail, also authorized to receive tax assessment notices from the Bureau of Internal Revenue?
  7. Can the intrinsic validity of the issuance of a tax assessment notice be raised and ruled upon by the Court of Tax Appeals despite the belated filing of a protest?
  8. What are the guidelines for Pre-CREATE and CREATE Registered Business Enterprises (“RBEs“) to transfer registration and avail of the incentives under Republic Act No. 12066 (“CREATE MORE Act“) pending the effectivity of its Implementing Rules and Regulations?
  9. What is the tax treatment of the income of Philippine Amusement and Gaming Corporation (“PAGCOR“), its Licensees, and Contractees, from (i) gaming operations and (ii) non-gaming operations?
  10. What are the available venue options for the processing and issuance of an Electronic Certificate Authorizing Registration (“eCAR“) for One-Time Transactions (“ONETT“) involving the sale of personal property?

Please read the full text here or via this link. 

WRITTEN BY

For further information, please contact:

Carina C. Laforteza – SyCipLaw,
cclaforteza@syciplaw.com

Carina C. Laforteza – SyCipLaw

Ms. Laforteza, an expert in Philippine taxation and corporate law, with extensive experience in tax structuring, litigation, and mergers. She's a CPA and lecturer at UP College of Law.

Ms. Laforteza is an expert on Philippine taxation and her tax work ranges from tax structuring for corporations, individuals, estates, tax compliance, as well as tax-related litigation and arbitration, including safeguard measures investigations. She is also an experienced corporate lawyer and has handled mergers, acquisitions and divestments (including transaction structuring, documentation and due diligence), as well as financing work, where she has acted for both lenders and borrowers.

She is a professorial lecturer in taxation at the University of the Philippines – College of Law and was a bar examiner in Taxation in the 2020/2021 Bar Examination given by the Philippine Supreme Court. 

Ms. Laforteza is also a certified public accountant.

She has been ranked by Chambers Asia Pacific as a Pacific since 2010.

Link to corporate profile: https://syciplaw.com/lawyers/partners/CCLaforteza

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