The August 2023 issue covers the following tax issues:
- May the ruling in the 2011 case of Commissioner of Internal Revenue v. Filinvest (“Filinvest”),
that instructional letters, journal and cash vouchers evidencing advances to affiliates qualified
as loan agreements upon which Documentary Stamp Tax (“DST”) may be imposed, be applied
retroactively against a taxpayer who did not obtain a prior favorable ruling from the Bureau
of Internal Revenue (“BIR”)?
- Can the Deputy Commissioner of Internal Revenue re-open a case for deficiency taxes after the
finality of a Final Decision on Disputed Assessment?
- Was the Estate Tax Amnesty extended?
- When does the five-year prescriptive period for tax evasion cases begin to run?
- May assessments be based solely on third-party information?
- How can Board of Investments (“BOI”) Registered Business Enterprises (“RBEs”) avail
themselves of the VAT and customs duty exemption on the importation of capital equipment,
raw materials, spare parts, or accessories?
- How may an RBE obtain a CNLA to avail itself of the VAT and customs duty exemption on
the importation of capital equipment, raw materials, spare parts, or accessories?
- Are RBEs registered with an IPA prior to the CREATE Act exempt from local business
taxes, fees, and charges after the effectivity of the CREATE Act?
- Are Independent Power Producers (“IPPs”) entitled to a reduction and condonation of real
property taxes (“RPT”) on their property, machinery and equipment used in the generation
and distribution of electric power?
- How can domestic corporations declare tax-exempt dividend income when such income was
received from multiple foreign sources?
Please read the full text here or via this link.
