The Dollar Margin Fee is Not a Tax

October 19, 1959 BIR RULING NO. 539-59 Messrs. Sycip, Gorres, Velayo & Co. 490 San Luis, Manila Gentlemen : I have the honor to refer to our letter to you dated August 14, 1959, marked as BIR Ruling No. 376. casia In said letter, we said that the dollar margin fee is a tax. Upon further study of the nature of said fee, however, we observed that it was intended not as a tax but as a currency measure. Our statement in our letter to you that the dollar margin fee in a tax is, therefore, deemed rectified accordingly. We are, therefore, modifying our ruling No. 376, series 1959, more specifically the 1st ruling therein, to read as follows: "1. The dollar margin fee is not a tax. Such being the case, dollar margin fee expended by resident-citizens or alien individuals in remitting money abroad are deductible for purposes of the income tax only if expended in accordance with the provisions of section 30 (a) (1) of the Tax Code; otherwise, they are not deductible." The second ruling contained in our letter in question, however, stands. Please be guided accordingly. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue