Non-Resident Alien Engaged in Trade or Business in the Philippines Subject to Income Tax

August 26, 1985 BIR RULING NO. 143-85 22-a-1 082-84 143-85 S i r : This refers to your letter dated May 27, 1985 requesting a ruling as to whether your client, Mr. George F. McBride is subject to income tax imposed by Section 21 of the Tax Code based on his entire net income received from all sources in the Philippines. It is represented that Mr. George McBride, an American citizen came to the Philippines under a temporary visitor's visa which admission status was later on changed to that of a pre-arranged employee during his stay in the Philippines for the period from September 28, 1984 to September 28, 1985, employed by International Flavors and Fragrances (Philippines), Inc. as its Director of Flavor Technical Services to train Filipino Technicians on flavor technology. In reply, please be informed that under the foregoing representation, Mr. George F. McBride is considered a non-resident alien engaged in trade or business in the Philippines and is, therefore, subject to income tax imposed by Section 21 of the Tax Code based on his entire net income received from all sources in the Philippines. (Sec. 22(a)(1), Tax Code) Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner