Profits Received on the Sale of Stocks of a Philippine Corporation
BIR Ruling No. 399-59 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Aug 12, 1959
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August 12, 1959 BIR RULING NO. 399-59 Messrs. Thomas, Beedy, Nelson & King Attorneys-at-Law 315 Montgomery Street San Francisco 4, U.S.A. Attention : Marie M . Nelson Gentlemen : Reference is made to your letter of June 2, 1959 inquiring whether it is necessary for an American citizen, resident in the United States, to file a Philippine income tax return and pay income tax to the Philippine Government on profits received on the sale of stocks of a Philippine corporation. In reply thereto, I have the honor to inform you that the gains derived from the sale of stocks of Philippine corporations are subject to Philippine income tax regardless of the place where the sale is made. Your query is, therefore, answered in the affirmative. However, this stand of the Bureau of Internal Revenue of the Philippines has been appealed to the Supreme Court (Collector (now Commissioner) of Internal Revenue v. Anglo California National Bank, as trustee for Calamba Sugar Estate, Inc., G.R. No. L-12476) and is now pending decision by said Court. prcd Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue for the Philippines
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