BIR Ruling

April 2, 1974 Cavite Farms Corporation Suite 315 Don Santiago Bldg. 1344 Taft Avenue, Manila Gentlemen : This refers to your letter dated March 29, 1974 requesting a ruling whether as a corporation whose fiscal year ends July 31, 1973, you may be subjected to investigation after having availed of the amnesty under Presidential Decree No. 370. casia In reply, I have the honor to inform you that under Section 2(b) of Revenue Regulations No. 2-74 dated January 14, 1974 implementing Presidential Decree No. 370, the term "previously untaxed income and/or wealth" in the case of a juridical person includes those which it "failed to declare for internal revenue tax purposes in any taxable year prior to January 1, 1973". The term "taxable year" means the calendar year, or the fiscal year ending during such calendar year, upon the basis of which the net income is computed under Title II of the Tax Code. (Sec. 84(o), Tax Code). In your case, therefore, the amnesty return which you filed under Presidential Decree No. 370 covers the taxable year up to December 31, 1972. Such period covered by the amnesty return is no longer subject to investigation. However, the remaining period of the fiscal year (January 1, 1973 to July 31, 1973) is still subject to investigation, the same being not covered by the amnesty. cdt Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR.