BIR Ruling [UN-176-B-94]

June 8, 1994 BIR RULING [UN-176-B-94] King Capuchino, Tan & Associates 2nd Floor, Belman II Bldg. Quezon Avenue corner Cordillera Sts. Quezon City, Metro Manila Attention: Atty . Lincoln L . Tan, Jr . Gentlemen : In reply to your letter dated February 10, 1994, please be informed that your offer to compromise for and in behalf of your client, Maricalum Mining Corporation (MMC), 2283 Pasong Tamo Ext., Makati, Metro Manila, its deficiency final withholding tax for the period January to September 1988 involving the amount of P11,283,491.00 under Assessment Notice and Letter of Demand both Numbered FAS-2-88-93-005107 and both dated December 1, 1993 by paying the amount of P2,697,803.68 representing the basic 15% withholding tax on the total interest paid of P17,985,357.85 for the period January to September 1988 without interest and surcharges under Section 204 of the Tax Code, as amended is hereby accepted. You are therefore, requested to pay to this Office the amount of P2,697,803.68 within fifteen (15) days from receipt hereof; otherwise, this compromise settlement shall have no further force and effect, in which case, this Office will enforce collection of the full amount of aforementioned tax liabilities without further notice. Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue