Taxes Payable by the Corporation Corresponding to the Functions

June 15, 1959 BIR RULING NO. 283-59 Messrs. Valera, Reyes, Mogarte and Associates Suite 207 Roces Hermanos Bldg. 437 Rizal Avenue, Manila Gentlemen : Reference is made to your letter dated June 6, 1959 stating the following: "This corporation, I-H, Inc., was organized and registered with the Securities and Exchange Commission, to act as financial, commercial, or general agent, representative, consultant, manager, or factor, or to undertake the promotion and general management for any person, corporation, or other judicial entity of business interests of all kinds and nature, including the investment of money in any profitable undertaking, the purchase and sale of properties and securities, the collection and receipt of money and the like, or otherwise engage in the business of management and consultant for others; and to make advances in behalf of, and to lend money to, its patrons, customers and others, and generally to carry out all operations, transactions and negotiations lawfully undertaken by individual capitalists." You now request information as to the taxes to which the corporation is subject. In reply thereto, I have the honor to inform you as follows: 1. For its management services, it is subject to tax as independent contractor. 2. For the purchase and sale of general merchandise graduated fixed tax. 3. For the purchase and sale of real property real estate dealer. 4. For the purchase and sale of securities dealer in securities. 5. As collecting agency business agent. 6. For lending money to its patrons, customers, and others lending investor. 7. If it negotiates the purchase and/or sale of merchandise between seller and buyer-commercial broker. The foregoing are the taxes payable by the corporation corresponding to the functions indicated, if actually performed. This statement is not exclusive. Generally, the corporation is liable to taxes corresponding to the activities undertaken by it. cdll Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue