Issuance of a Certification Authorizing the Transfer of Title to Real Property
BIR Ruling No. 234-89 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Nov 20, 1989
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November 20, 1989 BIR RULING NO. 234-89 21 (e) 020-87 234-89 Gentlemen : This refers to your letter dated July 20, 1988 requesting confirmation of your opinion to the effect that Revenue Memorandum Order No. 33-81 as amended by Revenue Memorandum Order No. 18-82 prior to its revocation by RMO No. 29-86 applies to mortgage foreclosure sales made prior to September 3, 1986. It will be noted that RMO No. 33-81, as amended by RMO No. 18-82 allowed the issuance of a certification authorizing the transfer of title to real property classified as capital asset even before payment of the capital gains tax, if purchased by a bank, finance or insurance company thru a mortgage foreclosure sale. In reply, please be informed that your opinion is hereby confirmed. RMO No. 29-86 specifically provides that the same "shall take effect immediately on the date this Order is issued (September 3, 1986) . . .." In other words, RMO No. 29-86 has prospective effect and shall apply to real property purchased by a bank, finance and insurance company purchased on or after September 3, 1986 thru mortgage foreclosure sales. Very truly yours, (SGD.) VICTOR A. DEOFERIO, JR. Deputy Commissioner
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