Grant of Exemption to Planters-Members of the Talisay-Silay Planters' Cooperative Marketing Association

June 13, 1958 BIR RULING NO. 312-58 Talisay-Silay Milling Co., Inc. Talisay, Negros Occidental Gentlemen : Reference is made to your letter dated June 5, 1958 inquiring as to whether or not the planters-members of the Talisay-Silay Planters' Cooperative Marketing Association, Inc. ceased to exist as registered planters of that Mill District, the Association having allegedly absorbed their legal personality, in view of the grant of exemption from the 2% tax to said Association. In reply thereto, I have the honor to inform you that, for purposes of the exemption under Act 3425, as amended, the question of whether or not the associations organized thereunder absorbed the legal personality of their members is not considered. So long as any such association meets the requirements of the law, exemption will lie even to the members, as decided in the case of Calamba Sugar Planters' Cooperative Marketing Association, Inc., vs. Collector of Internal Revenue, C.T.A. Case No. 216. LLjur Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue