Professional Documents
Culture Documents
TAX1
TAX1
INCOME HEALTH
RECOVERY OF LOST PROFITS *you have ability t pay taxes if you have sale of
goods/services
➢ Lost of profits = maintains/do not
decrease *increase in fv of asset/decrease in liabilities
➢ increases net worth that increases net worth are not income for
➢ return on capital taxation purposes
➢ insurance, legal suits, indemnity
TYPES OF TRANSFERS
contracts
1. Bilateral transfers/exchanges – income
tax; onerous transactions
CAPITAL ITEMS DEEMED WITH INFINITE a. Sale
VALUE b. Barter
2. Unilateral transfers – transfer tax;
➢ no measurement of value gratuitous transactions
➢ compensation for loss = return of capital
a. Succession (transfer upon MODE OF RECEIPT/REALIZATION
death) BENEFITS
b. Donation
1. Actual receipt – physical taking of
3. Complex transactions
income (cash/property)
a. Partly
2. Constructive receipt – no physical taking
*FV-SP=Transfer Tax but effectively benefitted
a. Offset of debt in consideration for
*SP-Cost=Income tax
the sale of goods/services
b. Deposit of income
c. Matured detachable interest
ANOTHER ENTITY coupons on coupon bonds not
➢ Natural yet encashed
➢ Juridical d. Increase in the capital of a
partner from the profit of
TAXABLE ENTITIES partnership
➢ Separate entities
o Relatives
o Corporations INFLOW OF WEALTH WITHOUT INCREASE
o Partner & partnership IN NET WORTH
o Parent company & subsidiaries ➢ No benefit = no income
o Sister companies o Receipt of property in trust
NOT TAXABLE ENTITIES o Borrowing of money under
obligation to return
➢ Sales of home office to branch office ▪ If no intention to return,
➢ Businesses of a proprietor income
PRESUMPTIONS
CORPORATE TAXPAYERS
➢ If citizen = resident
DOMESTIC
➢ If alien = resident
➢ Corporation organized in accordance ➢ If NR alien = NETB
with PH laws ➢ If corp = domestic
➢ Incorporates in PH even in controlled by ➢ If foreign corp = non-resident
foreigners
FOREIGN
*calendar year – individual, corp
➢ Organized in a foreign law
*fiscal year – corp only
RESIDENT FOREIGN CORPORATION
➢ Operates and conducts business in PH
through permanent establishment
(branch)