BIR Ruling No. 147-83

August 10, 1983 BIR RULING NO. 147-83 Gentlemen : This refers to the acquisition by Caltex (Philippines), Inc. (CPI) of the stocks of Mobil Petroleum Corporation (Mobilpet) in Mobil Oil Philippines, Inc. (MOPI) for US $40 million. cdti It appears that after said acquisition, CPI will liquidate MOPI. This will result in the transfer to CPI as the lone stockholder of MOPI of the latter's fixed assets, in cancellation and redemption of MOPI's entire issued and outstanding capital stock in the hands of CPI. You now request that CPI be entitled to a stepped-up basis of the said fixed assets of MOPI up to the Philippine currency equivalent to US $40 million, for depreciation purposes. In reply, I have the honor to inform you that your request is hereby granted. Accordingly, such stepped-up basis should be spread over the remaining useful lives of said fixed assets. The composite remaining useful lives of such assets shall not be less than eight (8) years. aisadc Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue