BIR Ruling No. 347-61

August 1, 1961 BIR RULING NO. 347-61 Messrs. Ponce Enrile, Siguion Reyna, Montecillo and Belo Seventh Floor, Soriano Building Manila Gentlemen : Reference is made to your letter dated July 18, 1961 requesting authority to file the income tax return of your client, Metro-Goldwyn-Mayer International, Inc., on the basis of the fiscal year ending August 31, 1961. cdta It appears that this Office previously authorized the member companies of the Motion Picture Export Association of America, which includes your client, to change their basis of returning their income from Philippine sources from the fiscal year to the calendar year basis and accordingly allowed to file on April 15, 1960 their income tax returns for the period from the end of their fiscal year in 1959 to December 31, 1959. This request is now made because of General Circular No. V-334 dated April 12, 1961 which provides that all the figures used in the computation of the cost of distribution and exhibition rights or the cost of production, as the case may be, shall be certified by an independent certified public accountant and such certification shall be authenticated by a Philippine consular official. You stated further that because the parent company of Metro-Goldwyn-Mayer basis ending on August 31st, additional expenses will be incurred by it in securing separate audit and certified statements. In reply, I have the honor to inform you that, under the prevailing circumstances, your request is hereby granted, but the income reported in the initial return under the new accounting period shall be placed on the annual basis. Accordingly, your client may file its income tax return for 1961 on the basis of the fiscal year ending August 31, 1961. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue