Managing Corporations are Not Independent Contractors

August 12, 1960 BIR RULING NO. 355-60 L. R. Aguinaldo & Co., Inc. 600-620 Echague, Manila Gentlemen : In reply to your letter dated May 27, 1960, I have the honor to inform you that this Office is of the opinion that managing corporations are not independent contractors within the purview of section 191 of the National Internal Revenue Code and are therefore, exempt from the tax prescribed therein. In accordance with the aforesaid ruling, you will be exempt from the contractor's tax prescribed in section 191 of the Tax Code should you act as manager of other companies in accordance with the proposed employment contract, a copy of which is attached to your letter. However, you will be subject to income tax and residence tax on whatever income is received by you from such employment contract. Very truly yours, MISAEL P. VERA Deputy Commissioner of Internal Revenue