BIR Ruling [DA-072-99]

February 5, 1999 BIR RULING [DA-072-99] 1st Indorsement January 8, 1999 Referred to the Revenue District Officer, Revenue District No. 43, Pasig City, Revenue Region No. 7, Quezon City, the herein xerox copy of BIR Ruling Nos. 277-93 and 278-93 both dated June 28, 1993 issued to UNIVERSAL ROBINA CORPORATION , 110 E. Rodriguez Avenue, Pasig City and CFC CORPORATION , E. Rodriguez Avenue, Pasig City, respectively, relative to the declaration of property dividends and the subsequent exchange of said property dividends for shares of stock of a corporation under then Section 34(c)(2) of the Tax Code (now Section 40(C)(2) and (6)(c) of the Tax Code of 1997) which has been previously referred to that Office for necessary investigation. Moreover, you were likewise requested to ascertain whether there has been a subsequent sale or disposition of the assets received as property dividends by JG Summit Holdings, Inc. (JGSHI), the selling price thereof and whether the taxes due thereon has been paid. LexLib However, if no investigation has as yet been conducted by that Office on the matter, it is requested that the docket of the case be forwarded to the Office of the Commissioner as soon as possible. (SGD.) SIXTO S. ESQUIVIAS IV Deputy Commissioner Legal & Enforcement Group