United Coconut Planters Bank (UCPB)

June 15, 2021 BIR RULING NO. OT-205-21 COCOFED vs. Aquino, et al. , G.R. No. 217965; COCOFED, et al. vs. Republic , G.R. Nos. 177857-58 & 178193; Ursua vs. Republic , G.R. No. 178193; BIR Ruling No. 675-2017; BIR Ruling No. 824-2018 United Coconut Planters Bank (UCPB) UCPB Corporate Offices 7907 Makati Avenue, Makati City Attention: AAA _______________ Gentlemen : This refers to your letter dated April 19, 2021 requesting for legal opinion on the tax implications of the cancellation of 1,699,749,538 shares of investment of Coconut Industry Investment Fund (CIIF) Trust Fund No. 81-586 maintained in UCPB Trust Banking, and the issuance of new shares of equivalent number in the name of the Republic of the Philippines. The issuance of said shares is to give effect to and implement the Supreme Court's decisions in Confederation of Coconut Farmers Organization of the Philippines vs. Aquino, et al. , 1 COCOFED, et al. vs. Republic of the Philippines 2 and Danilo S. Ursua vs. Republic of the Philippines . 3 DETACa It is represented that the 1,699,749,538 shares were registered in the name of the following CIIF Companies: Name of Corporation Number of Shares 1. Cagayan de Oro Oil Mills 141,644,027 2. Granexport Manufacturing Corp. 200,749,829 3. San Pablo Mfg. Corp. 113,769,408 4. Legaspi Oil Mills 141,145,323 5. Southern Luzon Coco Oil Mills 46,357,929 6. UCPB-CIIF Finance & Dev. Corp. 8,750,000 7. United Coconut Planters Life Ass. 255,823,689 8. United Coconut Chemicals, Inc. 681,985,073 9. Iligan Bay Express Corporation 9,526,260 10. Ten Trading Companies 4 99,998,000 Total 1,699,749,538 =========== The ab`ing is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. G.R. No. 217965, August 8, 2017. 2. G.R. Nos. 177857-58, January 24, 2012. 3. G.R. No. 178193, January 24, 2012. 4. Mt. Boribing Agricultural Commodities, Inc.; Maopay Agricultural Commodities, Inc.; Malipayon Agricultural Commodities, Inc.; Lamitan Peak Agricultural Commodities, Inc.; Mactan Agricultural Commodities, Inc.; Lamon Bay Agricultural Commodities, Inc.; Mt. Tuayan Agricultural Commodities, Inc.; Mt. Mandalangan Agricultural Commodities, Inc.; Sharp Peak Agricultural Commodities, Inc.; Mt. Bulusan Agricultural Commodities, Inc. 5. BIR Ruling No. 675-17 dated December 29, 2017 and BIR Ruling No. 824-2018 dated May 7, 2018. 6. Ibid . 7. Ibid .