BIR Ruling

May 25, 1973 Ravelo & Velante Law Office Attorneys-at-Law Suite 303, 3rd Floor 99 Dasmarias Bldg. Dasmarias, Manila Gentlemen : This refers to your letter dated May 18, 1973, requesting advice on whatever your client, a resident alien, who left the Philippines before Martial Law was declared and was abroad before the expiry period of Presidential Decree No. 23 and could not avail himself of the amnesty on April 2, 1973 is embraced by the provisions of Presidential Decree No. 174. In reply, I have the honor to inform you that considering that your client is a permanent resident of the Philippines and considering further that it was physically impossible for him to take advantage of the tax amnesty under Presidential Decree No. 23, it is believed that his case comes within the purview of the provisions of Presidential Decree No. 174, and accordingly, he may file the proper amnesty return at any Philippine Consulate abroad. Very truly yours, CONRADO P. DIAZ Acting Commissioner of Internal Revenue