BIR Ruling

January 16, 1975 Joaquin Cunanan & Co. 8th Floor, Rufino Bldg. 6784 Ayala Avenue Makati, Rizal Gentlemen : This refers to your letter dated September 19, 1974 requesting a ruling on a query stated as follows: "A, an individual, purchased shares of stock of Atlas Consolidated Mining sometime in 1968. In September 1970, the Board of Directors of Atlas Consolidated Mining approved a resolution declaring 50% stock dividend payable on December 11, 1970 to stockholders of record as of November 23, 1970. In 1973, A sold all his Atlas Consolidated Mining shares (the original purchase and stock dividends). Query: "Is the sale of the stock dividend acquired after November 5, 1970 subject to capital gains tax or stock transaction tax?" In reply thereto, I have the honor to inform you that under the foregoing facts, the selling price of the stock dividends is subject to the stock transaction tax, the same having been acquired by the seller after November 5, 1970. cdta Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN 1601-593-5