BIR Ruling No. 015-64

March 16, 1964 BIR RULING NO. 015-64 Messrs. Ross, Selph & Carrascoso Attorneys-at-Law P. O. Box 781 Manila Gentlemen : This is with reference to your letter dated February 24, 1964, requesting our opinion as to whether or not a corporation which is exempt from the payment of income tax under Section 27 of the National Internal Revenue Code is subject to both Class C and C-1 residence taxes. In reply thereto, I have the honor to inform you that pursuant to Section 2 of Revenue Regulations No. 1, the term, "'corporation' includes a duly incorporated company, partnership, joint stock company, joint account (cuenta en participation), insurance company, or any other association no matter how created or organized and irrespective of the purpose or purposes thereof". Consequently, even corporations exempt from the payment of income tax under Section 27 of the Tax Code are subject to the residence taxes. However, such corporations which do not own real property, nor earn income from sources other than that for which they are organized are not subject to the additional residence tax. cdll Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue