Tax Liability of a Resident Alien

January 23, 1959 BIR RULING NO. 049-59 2nd Indorsement Returned to the Regional Director, B.I.R. Regional District No. 2, San Fernando, Pampanga. It appearing that Mr. Bill D. Craft has established his residence in the Philippines even before his employment at the Pomeroy-Hawaiian Dredging-Bechtel Corporation, the exemption from income tax prescribed under the provisions of Article XII, Section 2 of the Base Treaty Agreement cannot apply to him. Said law reads as follows: "No national of the United States serving in or employed in the Philippines in connection with the construction, maintenance, operation or defense of the bases and residing in the Philippines by reason only of such employment, or his spouse and minor children and dependent parents of either spouse, shall be liable to pay income tax in the Philippines except in respect of income derived from Philippine sources other than the United States sources." Accordingly, Mr. Bill Craft is subject to Philippine income tax. cdpr (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue