BIR Ruling No. 118-61

February 20, 1961 BIR RULING NO. 118-61 Mr. Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants 450 San Luis, Manila Gentlemen : This is in connection with your letter dated February 4, 1961 requesting a ruling on the question of whether or not the document denominated "Trust Agreement", a specimen of which is attached to your letter, is subject to documentary stamp tax. LLphil Under the Trust Agreement, the Truster will entrust his contribution to be applied by the latter, through the Plan Managers, as payment of the Trustor's insurance premium and a portion thereof will be invested by the Trustee through the Plan Managers for and in behalf of the Trustor. In other words, the Trustor who is the principal will deliver property to another called the Trustee, for disposition in accordance with the conditions of the Trust Agreement. A document which authorizes another to administer or otherwise dispose of the property of a principal is subject to the documentary stamp tax of sixty centavos prescribed in Section 230 of the National Internal Revenue Code. In view of the foregoing, the aforesaid "First Agreement" is subject to the documentary stamp tax of sixty centavos prescribed in Section 230 of the Tax Code. LLjur Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue