TAX Notes

Umangay
Julo
Vargas

RECIT PAGES:
1. 193
2. 211
3. 213
4. 212
5. 214

Issuances Issued by the CIR -211

1. RR
2. RMO
3. RMC
4. RAO
5. RDAO
6. RSO
7. BIR Rulings
a. BIR Rulings
b. VAT Rulings
c. ITAD
i. Tax treaties
d. Rulings thru delegated authorities or unnumbered rulings
8. RAMOs
9. RMR
10. RB
11. RTAO

Cases:
1. Deutsch Bank Case - 241
2. Philippine Bank of Communications – Revenue Issuances - 229
a. Court cannot modify law
3. CIR v CA
4. Medina Case 254
a. Nature of the CIR commissioners Power to Make Assessments
5. Sy Po Case – 258
6. Cir v Kudos Metal - 260

Topics:
1. Kinds of Rulings
2. Non retroactivity of Revenue Issuances or Rulings
a. Sec 246
i. When will retroactivity be allowed
3. Powers of the Commissioner – p244
 a. CIR may issue subpoena duces tecum
b. Sec 5
c. Sec 6 – 247
4. Best evidence obtainable rule – 258
a. BIR has no excuse to not conduct the the audit since may pwedeng
gawin ang BIR to have the correct report
5. Sources of Internal Revenue - 282

TRAIN LAW
Now when you want to sell
What value are you supposed to follow? Tax base is FMV
And what is tax? CGT
For purposes of CGT what is ued? Zonal Value

In Train Law, whole country is divided in to zones

> CIR is now mandated to conduct periodic reappraisal once every 3 years
- zonal value must be published in newspaper of general circulation
- the reappraisal is mandated na now in Train Law

Before kasi laging issue is nahuhuli si BIR sa zonal value

ASSIGNMENT
Sabi ni atty we can go to her office after final exams
Room 411 – for makeup