American Nationals Either Born in the Philippines or Residents in this Country Prior to their Employment in U.S. Bases

1970 BIR RULING NO. 030-70 American nationals who were either born in the Philippines or were residents in this country prior to their employment in U . S . bases . American presently working in U.S. Bases in the Philippines who were either born in the Philippines or were residents of this country prior to their employment in said bases, are not included as among those exempt from income tax by virtue of the provision of Sec. 2, Art. XII of the Military Bases Agreement. This is so because under said provision, only nations of the United States who are working in U.S. Bases and residing in the Philippines by reason only of such employment enjoy tax exemption. When the American nationals were already residing in the Philippines prior to their employment, it is clear that they did not reside here by reason of their employment in the base. aisa dc Being resident aliens in the Philippines said American nationals are required to file Philippine income tax returns, regardless of whether their gross income was derived from sources within or without the Philippines. (Sec 45(a)(1)(B), Tax Code, as amended by Republic Act No. 6110).