Registration of Confirmatory Receipts of Subscription Payment

February 5, 1960 BIR RULING NO. 094-60 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants P.O. Box 589, Manila Gentlemen : Reference is made to your letter of the 1st instant, requesting a ruling as follows: cdt "On behalf of our client, FMF Life Insurance Co. (FMF LIC), we would like to secure a ruling from your Office based on the following facts: "'FMFLIC' is a company still in the process of incorporation. It executed an agreement with the Investment Planning Corporation of the Philippines (IPCP) whereby the latter as its underwriter, shall collect subscriptions to the shares of stock of the FMFLIC. To protect the interest of the paying investors, IPCP decided to issue a confirmation receipt (a sample copy of which is attached hereto), which advises the investor that his money was used in payment of his subscription to the FMFLIC shares. This confirmatory receipt is similar to a 'Broker's Advise' issued by a stockholder. "Under the foregoing facts, will it be necessary to register said confirmatory receipts of subscription payment before using the same in accordance with the Bookkeeping Regulations, notwithstanding the fact that FMFLIC is still in the process of incorporation and has not yet actually engaged in insurance business?" In answer thereto, I have the honor to inform you that, under the circumstances presented above, the receipts in question must be presented for approval and registration prior to the use thereof, pursuant to section 19 of Revenue Regulations No. V-1, as last amended by Revenue Regulations No. V-45. prcd Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue