BIR Ruling

August 11, 1975 Messrs. De Asis & Hernando Attorneys-at-Law 3rd Floor, Concepcion Building Muralla Cor. Victoria Sts. Intramuros, Manila Attention: Atty . Cesar D . De Asis For the Firm Gentlemen : This refers to your request for clarification on behalf of your client, the Princeton Exploration, Corporation, a holder of 150 lode claims situated in the Municipality of Taft and Sulat, Province of Eastern Samar, on whether or not as a result of Letter of Instruction No. 184 issued by the President suspending the processing of all applications for lease of mining claims situated in Samar, the payment of occupation fees on the said claims pursuant to the provisions of Section 241 of the Tax Code, as amended, is also suspended. cdta In reply thereto, I regret to inform you that under the foregoing facts, the payment of the occupation fees by your client is not suspended. Pursuant to the provisions of Section 241 of the Tax Code, as amended, the occupation fee arises from the date of the registration of the claim in the Office of the Mining Recorder, and on the same date every year thereafter, until the lease covering the mineral claim shall have been granted. Besides, your client has not been deprived of its mining because what was suspended by the President is the processing of the claim before the lease of the mining claim is granted. In fact, as ruled by the Bureau of Mines your client can continue exploration work in the area. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5