The Dollar Margin Fee is a Tax
BIR Ruling No. 376-59 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Aug 14, 1959
Full text
August 14, 1959 BIR RULING NO. 376-59 Messrs. Sycip, Gorres, Velayo & Co. 490 San Luis, Manila Gentlemen : In reply to your letter dated August 12, 1959, I have the honor to inform you as follows: 1. The dollar margin fee is a tax. Such being the case, dollar margin fees expended by resident-citizens or alien individuals in remitting money abroad are deductible for purposes of the income tax, pursuant to section 30 (c)(1) of the Tax Code. 2. Dollar margin fees expended by non-resident foreign corporations and alien individuals not engaged in trade or business in the Philippines in connection with the remittance to them of their income from Philippine sources, such as interests, dividends, royalties or other fixed and determinable periodical gains or profits, are not deductible for purposes of the income tax payable by them. LLjur Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue
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