Taxability of Resident-Aliens

October 2, 1958 BIR RULING NO. 634-58 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants P.O. Box 589, Manila Gentlemen : With reference to your letter dated February 20, 1958, I have the honor to inform you as follows: llcd Resident-aliens are, for income tax purposes, placed at equal footing with citizens of this country. A British subject who was employed in the Philippines for more than one year is considered a resident of this country during the period of his employment and as such, is entitled to the personal exemptions allowed to citizens of this country. However, a resident-alien who leaves the Philippines before June 30, and does not return before the end of the calendar year, is only allowed a personal exemption in an amount equal to the exemptions allowed by the income tax law of his country to citizens of the Philippines not residing in such country, because his status on December 31, is that of a non-resident alien who was engaged in trade or having income in the Philippines. It appearing that, under the United Kingdom Inland Revenue Act, "individuals, regardless of their nationality, who are regarded as resident in the United Kingdom in the income tax sense of the word, are entitled to the full personal allowances for any year in which they are resident, including a broken year of arrival or departure", the British subject in question is entitled to similar exemption but not to exceed the amount fixed as exemption for citizens or residents of the Philippines. (Sec. 22(e), Tax Code). cdta Very truly yours, (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue