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Retroactive Effect of RMO No. 29-86 Revoking RMO No. 33-81

BIR Ruling No. 020-87 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jan 26, 1987

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January 26, 1987 BIR RULING NO. 020-87 21 (e) 000-00 020-87 Gentlemen : This refers to your letter dated November 18, 1986, requesting information whether Revenue Memorandum Order No. 29-86 which revoked Revenue Memorandum Order No. 33-81, as amended by RMO No. 18-82 has retroactive effect. It will be noted that said RMO No. 33-81, as amended by RMO No. 18-82 allowed the issuance of a certification authorizing the transfer of title to real property classified as capital asset even before payment of the capital gains tax, if purchased by a bank, finance or insurance company thru a mortgage foreclosure sale. In reply, please be informed that said RMO No. 29-86 specifically provides that the same "shall take effect immediately on the date this Order is issued (September 3, 1986) . . . ." In other words RMO No. 29-86 has prospective effect and shall apply to real property purchased by a bank, finance and insurance company purchased on or after September 3, 1986 thru mortgage foreclosure sales. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner

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