Non-Deductibility of Dollar Margin Fees
BIR Ruling No. 444-59 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Sep 17, 1959
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September 17, 1959 BIR RULING NO. 444-59 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants 490 San Luis, Manila Gentlemen : In reply to your letter dated September 16, 1959, I have the honor to inform you that a domestic corporation cannot, for purposes of the income tax, deduct from its gross income dollar margin fees expended in connection with its remittance of dividends to non-resident foreign corporations which it agreed to absorb in favor of the latter because said fees are not actually its direct liability nor expended in connection with its business operations. cdtech Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue
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