Tax Position of a Lessee of Sugar Lands
BIR Ruling No. 337-58 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jun 24, 1958
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June 24, 1958 BIR RULING NO. 337-58 Messrs. Meer, Meer & Meer Suite 302-306 Singson Bldg. Plaza Moraga, Manila Gentlemen : Reference is made to your letter of the 17th instant, requesting the opinion of this Office on the tax position of your client, Mrs. Lourdes R. Osmea, based on the following facts: "Mrs. L. R. Osmea is the owner of sugar lands which she is leasing or renting to other parties at a stipulated rental value amounting to less than 20% of the assessed value of said sugar lands. Under Section 194(s) of the Tax Code, an owner of sugar lands subject to tax under Commonwealth Act No. 567 shall not be considered a real estate dealer." In reply thereto, I have the honor to inform you that if your client leases only sugar lands, she is not liable to the real estate dealer's fixed tax imposed by Section 182(s) on real estate dealers, pursuant to Section 194(s), which provides "that an owner of sugar lands subject to tax under Commonwealth Act Numbered Five hundred and sixty-seven shall not be considered a real estate dealer under this definition". cdpr Very truly yours, (SGD.) JOSE P. TRINIDAD Acting Commissioner of Internal Revenue
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