Corporation Engaged in Buying Stocks and Securities for Purposes of Investment

August 27, 1959 BIR RULING NO. 424-59 Home Investments Corporation Room 302 Martinez Bldg. Cor. David & Dasmarias Sts. M a n i l a Gentlemen : In connection with your letter dated January 28, 1959 requesting information as to the taxability of that corporation, I have the honor to inform you that according to investigation, that corporation is presently engaged in buying stocks and securities only for purposes of investment. If this is the only activity of the corporation, it is not subject to any internal revenue tax on business. This ruling is not, however, exclusive. Your liability to tax shall depend upon the actual business operations which you may undertake in the future. As a rule, therefore, we may state that, inasmuch as this Office is not confronted with the actual manner of your operations, it is incumbent upon you in the meantime to determine your tax status. From the primary and secondary purposes of your corporation as contained in your articles of incorporation, however, you may be liable to tax as stockbrokers, dealers in securities, lending investors, commercial brokers and independent contractors. Before using books of accounts, you must first present them for approval and registration. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue