BIR Ruling

April 16, 1997 The President Hongkong & Shanghai Banking Corporation 6780 Ayala Avenue Makati City Gentlemen : This refers to the Warrant of Garnishment No. N-B-3173-91 issued on the deposit of the late Mrs. Rosemarie T. de Toda in connection with the deficiency estate tax assessment issued by this Office against the estate of said decedent, involving the amount of P147,931,995.20 later revised/modified to P98,482,490.20 inclusive of increments incident to delinquency. Considering the payment by the estate of the amounts of P41,000,000.00 and P59,381,914.68 covered by Payment Forms 0605 dated January 28, 1997 and February 6, 1997 respectively, or a total of P100,381,914.68 inclusive of surcharge and interest computed up to the actual date of payment, in full and final settlement of the above-mentioned tax liability, the said warrant of garnishment issued on the deposit, and such other properties, tangible or intangible, of said taxpayer now in your possession, is hereby lifted and considered without force and effect. Please be guided accordingly. cdta Very truly yours, (SGD.) LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue