Maxima Equipment Company, Inc.

October 15, 2008 BIR RULING [DA-(C-096) 294-08] Maxima Equipment Company, Inc. 869 Quezon Ave. cor. Gen. Lim St. Quezon City Attention: Raul M. Ang President Gentlemen : This refers to BIR Ruling No. DA-169-2007 issued in your favor, confirming your tax exemption from capital gains tax and/or creditable withholding and documentary stamp taxes on the reconveyance of several parcels of land in Quezon City and in Cagayan de Oro City pursuant to the revocation of a Deed of Trust between your company as the Trustee and Maxima Machineries, Inc. (MMI) as the Trustor. In this connection, this Office as per certification issued by the Securities and Exchange Commission (SEC) on August 28, 2008, had come to know that the Certificate of Registration of MAXIMA MACHINERIES, INC., the herein Trustor, with SEC No. AS 96000240 has been revoked on March 15, 2004, for non-compliance with the reportorial requirements. Consequent thereto, at the time of the reconveyance of the subject properties by Maxima Equipment Co., Inc. (MECI), to MMI, the Trusteeship Agreement transferring the properties was no longer existing considering that MMI, the Trustor, had no more legal personality to perform corporate acts or to assume any trust arrangement under the aforementioned corporate name. It is, for all legal intents and purposes, no longer existing. In view of the above, you are hereby directed to pay the taxes due from the transfer of the properties, the 6% capital gains tax plus the corresponding interest and surcharges and the 1.5% documentary stamp tax pursuant to Section 196, both of the Tax Code of 1997. This ruling effectively revokes BIR Ruling No. DA-169-2007 dated March 22, 2007. EHSIcT Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service