Non-taxability of Surplus Arising from and Occasioned by an Increased Appraisal

April 29, 1958 BIR RULING NO. 249-58 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants 490 San Luis, Manila Gentlemen : Reference is made to your letter dated April 28, 1958 wherein you stated that your client, Insular Life Assurance Co., Ltd., has been carrying in its books its investments securities, and land and office building at their pre-war values, and that it is now planning to revalue said assets to their present values which are much higher. You now request this Office for a ruling on whether or not the resulting appraisal or revaluation surplus is subject to income tax. In reply thereto, I have the honor to inform you that such surplus arising from and occasioned by an increased appraisal is not taxable, there being actually no income realized by the company within the contemplation of Section 29(a) of the National Internal Revenue Code. cdti Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue