tAn estate tax is a tax on the right of the deceased person to transmit

his/her estate to his/her lawful heirs and beneficiaries at the time of

death." An estate, on the other hand, refers to all the money and
property that is owned by the deceased at the time of death.

 This was earlier disclosed by former senior associate justice Antonio

Carpio who revealed that when Marcos Sr. died in 1989, his estate tax
liability amounted to P23.29 billion. The Marcos heirs did not file the
estate tax return or paid such tax as required by law. With interest, the
amount would have grown to P203.8 billion pesos. Last December,
the Bureau of Internal Revenue (BIR) disclosed that they sent a
demand letter to the Marcoses about their tax liabilities.\

Indeed, according to the BIR, an estate tax is levied "based on the

laws in force at the time of death notwithstanding the postponement of
the actual possession or enjoyment of the estate by the beneficiary."
But this assumes that the said estate will eventually be inherited by the
heirs, which in the case of seized and forfeited assets is no longer
possible.
"All income is taxable no matter how you got it. In estate tax, as long as it’s in your name when you
died and you own it, it’s taxable.
Estate tax is the amount that's taken out of someone's estate upon their death.

The Civil Code provides: “Judicial decisions applying or interpreting the laws or the
Constitution shall form part of the legal system of the Philippines.”  

It is clear as day, beyond any shadow of doubt, that the estate tax assessment on the
Marcos Estate, in the principal amount of P23.3 billion pesos, had long become final,
executory, and unappealable as of December 1991 when the Marcoses failed to
protest the assessment within 30 days from receipt of the assessment. That was 29
years ago.  The decision of the Supreme Court affirming this estate tax assessment
became final and executory on March 9, 1999, or almost 25 years ago.

https://www.rappler.com/voices/thought-leaders/analysis-estate-tax-liability-marcos-estate/