Retroactive Effect of RA No. 2343

July 28, 1959 BIR RULING NO. 358-59 Dr. Arturo A. Alafriz & Associates Attorneys & Counsellors at Law Suite 404, Regina Bldg. Escolta, Manila Gentlemen : With reference to your letter dated July 2, 1959, I have the honor to inform you that, inasmuch as Republic Act No. 2343 (H.B. 1825), amending section 53(b) of the Tax Code, has provided for the retroactivity of its provisions, it is therefore the duty of this Office to apply the increased rates from January 1, 1959. The ruling of this Office dated February 13, 1953, as cited in your letter, finds no application in the present case. Accordingly, in the case of dividends paid prior to June 20, 1959, the date of approval of Republic Act No. 2343, the deficiency tax of 8% shall be withheld from subsequent payments to the same stockholder. If the recipients of such dividends ceased to be stockholders on June 20, 1959, such fact shall be reported to this Office together with information regarding the amounts of their dividends and tax withheld. In this connection, attention is drawn to subsection (c) of section 53 of the Tax Code, as amended, which requires every person under obligation to deduct and withhold any tax under said section, as well as under section 54, as amended, to make a return thereof and pay the amount withheld on or before April 15th of each year. aisadc Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue