Tax Exemption Granted to Domestic Insurance Companies suffering from Impairment of Capital

April 26, 1960 BIR RULING NO. 277-60 The Insular Life Assurance Co., Ltd. M a n i l a Attention : Mr . Miguel Ortigas Vice-President and Treasurer In reply to the query contained in your letter dated March 28, 1960, I have the honor to inform you as follows: The words "passage of the act", and similar expressions, in statutes, have equal reference to the time of their taking effect. (Roger vs. Voss, 6 Iowa (6 Clarke) 405, 408. Cited in Vol. 31A Words and Phrases, p. 9) "Ordinarily, "passage of an act" is understood as time when it is stamped with approval of requisite vote of both houses of legislature in constitutional manner, signed by presiding officer of each house, and approved by chief executive, but its "going in effect" means its becoming operative as a law. (State ex rel. Bishop v. Board of Education of Mt. Crab Village School Dist., Brown Country, 40 N. E. 3d 913, 919, 139 Ohio St. 427, cited in Vol. 31A Words & Phrases, p. 7) "The word "passage" used in connection with legislative enactments refers to a compliance with all forms necessary to give the enactment force and validity. (People v. Coffin, 117 N.E. 65, 87, cited in Ibid, p. 7) In view of the foregoing, domestic insurance companies suffering from impairment of capital are exempted from the premium tax beginning June 16, 1956, when Republic Act No. 1504 became effective upon its approval by the President of insurance companies from the premium tax cases on June 15, 1960, pursuant to Section 256 of the Tax Code, as amended by Republic Act No. 1504. cdi Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue