BIR Ruling

May 11, 1973 Philippine Bank of Communications P. O. Box 934 Manila S i r : In reply to your letter dated August 23, 1972, I have the honor to inform you that as held in our ruling of October 24, 1953, the transfer of certificates of stock by operation of law as in the case of intestate succession is not subject to the documentary stamp tax imposed in Section 213 of the Tax Code. The above ruling is supported by the decision in the case of United States vs. Seatle-First National Bank, 31 AFTR 225, which also involves transfer among others, of stocks by operation of law. It was held in this cited case that the transfer of the certificates of stock is not subject to the documentary stamp tax. cdtech Very truly yours, (SGD.) CONRADO P. DIAZ Acting Commissioner of Internal Revenue (Operations)