Salaries Received from FILOIL, Philippines and from the Gulf Oil (United States)

April 29, 1959 BIR RULING NO. 195-59 Mr. Samuel T. Baez 7th Floor Shurdut Bldg. Intramuros, Manila S i r : Reference is made to your letter dated April 28, 1959 stating the following: "My client, Mr. Burch E. Zehner, an American, is employed by the FILOIL, Philippines. He is under contract for three (3) years with the said firm. He receives salaries from the FILOIL aside from salaries due him from the Gulf Oil (United States) of which he is also an employee. "Will you please inform us about B.E. Zehner's tax liabilities on salaries being received by him in the Philippines with reference to income (salaries) received by him from the United States." Under the foregoing facts, I have the honor to inform you that your client is, during his employment, considered a resident of the Philippines. Accordingly, the salaries received by him from FILOIL, Philippines and from the Gulf Oil (United States) are both subject to Philippine income tax, pursuant to section 21 of the Tax Code, and to the basic and additional residence tax, pursuant to section 1 of C.A. No. 465. prcd Very truly yours, (SGD.) MELECIO R. DOMINGO Deputy Commissioner of Internal Revenue