Taxability or Non-taxability of L. R. Aguinaldo & Co., Inc.

January 16, 1959 BIR RULING NO. 025-59 L. R. Aguinaldo & Co., Inc 600-620 Echague Manila Attention : Mr . Marcelo Eugenio Treasurer S i r : In reply to your letter of even date requesting opinion on the taxability or non-taxability of your corporation should it act as manager of other corporations for a fee, I have the honor to inform you that as a rule, this Office considers corporations which manage the business affairs of another entity for a fee as independent contractors subject to the fixed and percentage taxes prescribed in Sections 182 and 191 of the Tax Code. Said corporations are also subject to the income and residence taxes. However, the facts stated in your letter are inadequate that we are not, for the present in a position to render a ruling on your query. For this reason, it is requested that you furnish us with more particulars about your case such as a copy, if any, of your management contracts, a description of the activities you will perform as manager, and other data pertinent thereto. Very truly yours, (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue