Facts: On June 26, 1995, petitioner and the National Irrigation Administration (NIA) entered into a build-operate-transfer (BOT) contract known as the “Amended and Restated Casecnan Project Agreement” (Casecnan Contract) relative to the construction and development of the Casecnan Multi-Purpose Irrigation and Power Project (Casecnan Project) in Pantabangan, Nueva Ecija and Alfonso Castaneda, Nueva Vizcaya. TheContinue reading “CE CASECNAN WATER and ENERGY COMPANY, INC., vs. THE PROVINCE OF NUEVA ECIJA, G.R. No. 196278, June 17, 2015“
Category Archives: Taxation 1
CIR vs Philippine Daily Inquirer March 22, 2017, G.R. No. 213943
Facts: Issues: 1.) Whether the CTA En Banc erred in ruling that petitioner’s assessment for deficiency VAT and income tax was adequately controverted by respondent; 2.) Whether the CTA En Banc erred in ruling that the petitioner’s right to assess respondent for deficiency VAT and income tax has prescribed; and 3.) Whether the CTA EnContinue reading “CIR vs Philippine Daily Inquirer March 22, 2017, G.R. No. 213943”
CIR vs Lancaster Philippines G.R. No. 183408, July 12, 2017
Facts: Petitioner Commissioner of Internal Revenue (CIR) In 1999, issued Letter of Authority (LOA) authorizing its revenue officers to examine Lancaster’s books of accounts and other accounting records for all internal revenue taxes due from taxable year 1998 to an unspecified date. After the conduct of an examination pursuant to the LOA, the BIR issuedContinue reading “CIR vs Lancaster Philippines G.R. No. 183408, July 12, 2017”
MEDICARD PHILIPPINES, INC VS. CIR (GR NO. 222743) APRIL 5, 2017
FACTS MEDICARD is a health maintenance organization (HMO) that provides prepaid health and medical insurance coverage to its clients. Individuals enrolled in its health care programs pay an annual membership fee and are entitled to various preventive, diagnostic and curative medical services provided by duly licensed physicians, specialists, and other professional technical staff participating inContinue reading “MEDICARD PHILIPPINES, INC VS. CIR (GR NO. 222743) APRIL 5, 2017”
Metropolitan Bank & Trust Company vs The Commissioner of Internal Revenue G.R. No. 182582 April 17, 2017
Facts: On June 5, 1997, Solidbank Corporation (Solidbank) extended a foreign currency denominated loan to Luzon Hydro Corporation (LHC), in the principal amount of US$123,780,000.00. With the agreement that LHC is bound to shoulder all the corresponding taxes, as well as the filing of tax returns and remittance of the taxes withheld to the BIR.Continue reading “Metropolitan Bank & Trust Company vs The Commissioner of Internal Revenue G.R. No. 182582 April 17, 2017”
BANCO DE ORO, ET AL VS Republic of the Philippines, et al G.R. No. 198756, August 16, 2016
FACTS The Bureau of Treasury (BTr) in a notice announced the auction of 10- year Zero-Coupon Bonds denominated as the Poverty Eradication and Alleviation Certificates or the PEACE Bonds on October 16, 2001, which the BTr states shall not be subject to 20% final withholding tax since the issue is limited to 19 buyers/lenders. AtContinue reading “BANCO DE ORO, ET AL VS Republic of the Philippines, et al G.R. No. 198756, August 16, 2016”
CIR v Goodyear Philippines, Inc. G.R. No. 216130, 03 Aug 2016
Facts: On 15 October 2008, respondent filed an application for relief from double taxation before the International Tax Affairs division of the BIR to confirm that the redemption of respondent’s preferred shares owned by an American company was not subject to Philippine income tax. Nonetheless, respondent still withheld and remitted 15% final withholding tax (FWT)Continue reading “CIR v Goodyear Philippines, Inc. G.R. No. 216130, 03 Aug 2016”
PILMICO-MAURI FOODS CORP., v. CIR G.R. No. 175651, September 14, 2016
FACTS [PMFC] is a corporation, organized and existing under the laws of the Philippines, with principal place of business at Aboitiz Corporate Center, Banilad, Cebu City. The books of accounts of [PMFC] pertaining to 1996 were examined by the [CIR] thru Revenue Officer Eugenio D. Maestrado of Revenue District No. 81 (Cebu City North District)Continue reading “PILMICO-MAURI FOODS CORP., v. CIR G.R. No. 175651, September 14, 2016”
CIR vs. Secretary of Justice
Facts: Metropolitan Cebu Water District (respondent) received a Preliminary Assessment Notice from the Bureau of Internal Revenue (BIR) for alleged tax deficiencies for the year 2000 in the total amount of P70,660,389.00, representing alleged deficiency income, franchise and value added taxes with surcharge and interest, as well as compromise penalties. MCWD filed a formal protestContinue reading “CIR vs. Secretary of Justice”
CIR V DLSU G.R. 196596 Nov. 9 2016
Facts In 2004, the Bureau of Internal Revenue (BIR) issued a letter authorizing it’s revenue officers to examine the book of accounts of and records for the year 2003 De La Salle University (DLSU) and later on issued a demand letter to demand payment of tax deficiencies for: Income tax on rental earnings from restaurants/canteens andContinue reading “CIR V DLSU G.R. 196596 Nov. 9 2016”
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