BIR Ruling
BIR Ruling • Bureau of Internal Revenue (BIR) Issuances • Rulings (Unnumbered) • Aug 25, 1977
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August 25, 1977 The Register of Deeds Office of the Register of Deeds Caloocan City S i r : This refers to your letter dated June 16, 1977 requesting a certification to the effect that the waiver made by all of the legitimate children of the late Felix H. Yoingco of their right to inherit and to participate in a piece of real property located in Caloocan City in favor of their mother, Mrs. Consolacion B. Yoingco by virtue of a "Deed of Extrajudicial, Partition with Waiver, and Sale" executed on April 25, 1976 is not subject to donor's (gift) tax. In reply, I have the honor to inform you that this Office is of the opinion and so holds that the inheritance renounced by the Yoingco children in favor of their mother, is not a donation but additional inheritance to the latter; hence no donor's (gift) taxes are due from the Yoingco children. (BIR Ruling No. 65-092 dated August 20, 1965). Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-P4519-F2828-A-8
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