BIR Ruling No. 101-63
BIR Ruling No. 101-63 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Dec 19, 1963
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December 19, 1963 BIR RULING NO. 101-63 Mr. Casiano M. de Vera Certified Public Accountant & Attorney-at-Law P. O. Box 1849, Manila S i r : In reply to your letter dated December 12, 1963, I have the honor to inform you that a person engaged in the business of buying race horse and training them for races for the purpose of eventually selling them for profit and/or entering them in races is not subject to tax on business. This for the reason that, while the activity is carried on for profit, nevertheless, it is not covered by any of the taxes imposed on business comprised in the Tax Code. It is understood, however, that the profits derived from the activity is subject to the income and additional residence taxes. Besides, the gains thus derived shall be considered as ordinary and net capital gains. Very truly yours, (SGD.) RAMON T. OBEN Acting Commissioner of Internal Revenue
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