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Should LOAs Be Revalidated?

By: Atty. Raida Argeli Grefiel on May 2,2024 The National Internal Revenue Code, as amended, (the “Tax Code”) authorizes the Commissioner of Internal Revenue (“CIR”) or his duly authorized representative to conduct audits, in light of the power of the Bureau of Internal Revenue (“BIR”) to assess...

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What is a False Tax Return?

By: Atty. Xela Leona D. Laqui on April 18,2024 Under Section 222 of the National Internal Revenue Code, as amended (“Tax Code”), the ten-year prescriptive period for the Commissioner of Internal Revenue (CIR) to assess tax applies in cases where a taxpayer files a false or fraudulent return with...

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Reimbursements among Multinational Enterprises: Taxable?

By: Atty. Sarah T. Ganto on April 5,2024 With the issuance of Revenue Memorandum Circular (“RMC”) No. 5-2024, as clarified by RMC No. 38-2024, on the taxation of cross-border services, another topic tackled by the said RMCs equally merits discussion: the taxation of reimbursements among multinational...

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There is more to the Create More Bill

By: Atty. Lew Earvin Manarin on March 14,2024 The Corporate Recovery and Tax Incentives for Enterprises Act (the “CREATE Act”) introduced amendments to our National Internal Revenue Code (“Tax Code”) which were aimed to eliminate tax uncertainty, offer tax assistance to struggling enterprises...

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