BIR Ruling No. 224-61

July 10, 1961 BIR RULING NO. 224-61 3rd Indorsement Respectfully returned to the Chief, Investigation Division the income tax case of Mr. Victor E. Lednicky with the information that this Office has consistently ruled that income tax paid to a foreign country can be allowed as deduction only in cases where the taxpayer has income from sources within such foreign country during the same year which is taxable in the Philippines. In the instant case the taxpayer has no income from sources outside the Philippines. It also appears that the taxpayer has not actually paid the tax to the foreign country as the collecting officer refused to accept payments in peso. Accordingly, he is not entitled to deduct the taxes claimed to have been paid by him to the United States Government. (SGD.) MISAEL P. VERA Deputy Commissioner of Internal Revenue