GSIS Tax Exemptions P.D. No. 1146 Revoked by P.D. No. 1177

January 21, 1982 BIR RULING NO. 018-82 34-00 000-00 018-82 Mr. Eduardo S. Lichauco Mrs. Josefina Trinidad Lichauco Avalon Condominium Ortigas Avenue, Greenhills San Juan, Metro Manila Sir/Madam : This refers to your letter dated March 10, 1981, stating that on December 6, 1980, the two of you entered into "An Agreement To Dissolve Conjugal Partnership" which was approved by the Court of First Instance of Rizal in a Decision rendered in Special Proceedings No. 9413 on January 20, 1981; and that to implement the abovesaid Agreement and Decision, Mr. Lichauco executed on March 12, 1981 a Deed of Quitclaim which was approved by the same Court in an order dated March 17, 1981. To preclude any difficulty in the registration of these documents, you now request a ruling that no liability to pay capital gains tax resulted on the basis of the abovestated facts. In reply, please be informed that inasmuch the Deed of Quitclaim executed by Mr. Lichauco merely entailed his waiver of any present and future claim, in favor of Mrs. Lichauco with respect to his share in the erstwhile conjugal house and lot at 1738 Banyan Road, Dasmarias Village, Makati, Metro Manila, in consideration for P1,000,000 representing Mr. Lichauco's share in the balance of the conjugal assets, thus ultimately leading to the dissolution of the conjugal partnership, no capital gains were realized nor loss incurred. Accordingly, no capital gains tax, as imposed under Sec. 34 of the Tax Code as amended by Batas Pambansa Blg. 37, is due from you under these particular circumstances. cdtech Very truly yours, RUBEN B. ANCHETA Acting Commissioner