12/1/20

TAXATION LAW
TRANSFER TAXES
MARVIN PATRICIO CAÑERO
Attorney-at-Law
Certified Public Accountant
Law Professor and Bar Reviewer in Taxation
Former Revenue Attorney – Bureau of Internal Revenue

ATTY. MARVIN P. CAN ERO, CPA 1 ATTY. MARVIN P. CAN ERO, CPA 2

CONCEPT AND NATURE:

ØEstate is a tax on the right to transfer property at death and on certain

transfers which are made by law equivalent to testamentary dispositions
and is measured by the value of the property .
ESTATE TAX ØIt is not a property tax but rather an excise tax imposed on the right to
transmit property; it is laid neither on the property nor on the transferor
or the transferee; it is an excise tax or privilege tax and its object is to tax
the shifting of economic benefits and enjoyment of property from the
dead to the living.
ØEstate taxation is governed by the statute in force at the time of death of
the decedent. The estate tax accrues as of the death of the decedent and
the accrual of the tax is distinct from theobligation to pay the same. Upon
the death of the decedent, succession takes place and the right of the
State to tax the privilege to transmit the estate vests instantly upon death.
ATTY. MARVIN P. CAN ERO, CPA 3 ATTY. MARVIN P. CAN ERO, CPA 4

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Imposition of Estate Tax

BAR: Antonia Santos, 30 years old, gainfully employed, is the sister of

Edgardo Santos. She died in an airplane crash. Edgardo is a lawyer and
he negotiated with the Airline Company and insurance company and ØThere shall be levied, assessed, collected and paid upon the
they were able to agree to a total settlement of P10 Million. This is transfer of the net estate as determined in accordance with
what Antonia would have earned as somebody who was gainfully Sections 85 and 86 of every decedent, whether resident or
employed. Edgardo was her only heir. Is the P10 Million subject to nonresident of the Philippines, a tax at the rate of six percent
estate tax? Reason briefly. (6%) based on the value of such net estate. (Sec. 84, NIRC)

ATTY. MARVIN P. CAN ERO, CPA 5 ATTY. MARVIN P. CAN ERO, CPA 6

Composition of the Gross Estate

Rule of Reciprocity

1. Residents and citizens

Ø all properties, real or personal, tangible or intangible, wherever ØNo tax shall be collected in respect to intangible personal property of
situated; NRA if the foreign country in which the NRA was a citizen and
resident grants Total Exemption or Partial Exemption for transfer tax
of any character or description in respect of intangible personal
2. Non-resident aliens
property of citizens of the Philippines not residing in that foreign
Ø only properties situated in the Philippines provided, that, with country. ( Sec. 104, NIRC)
respect to intangible personal property, its inclusion in the gross
estate is subject to the rule of reciprocity provided for under Section
104 of the Tax Code.

ATTY. MARVIN P. CAN ERO, CPA 7 ATTY. MARVIN P. CAN ERO, CPA 8

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Situs of Intangible Personal Property

1. BAR: William Smith, an American citizen, was a permanent resident
Ø General Rule: “mobilla sequuntur personam” of the Philippines. He died in San Francisco, California. He left 10,000
ØException: (a) when inconsistent with express provisions of statute ; (b) shares of San Miguel Corporation, a condominium unit at the Twin
when justice does not demand that it should be, as when the property has Towers Building at Pasig,
in fact a situs elsewhere. Metro Manila and a house and lot in Miami, Florida. What assets
Ø IPP having a situs in the Philippines ( Sec. 104, NIRC) shall be included in the Estate Tax Return to be filed with the BIR?
a) franchise which must be exercised in the Philippines;
b) SOB issued by any corporation or sociedad anonima organized or
constituted in the Philippines in accordance with its laws;
c) SOB by any foreign corporation 85% of the business of which is
located in the Philippines;
d) SOB issued by any foreign corporation if such shares, obligations or
bonds have acquired a business situs in the Philippines
e) shares or rights in any partnership, business or industry established
in the Philippines. ATTY. MARVIN P. CAN ERO, CPA 9 ATTY. MARVIN P. CAN ERO, CPA 10

Inclusions in the Gross Estate [Section 85(A), NIRC]

Factors to be considered in determining whether the transfer is in
A. Decedent's Interest
contemplation of death or not:
B. Transfer in Contemplation of Death
a) transfer by trust or otherwise, in contemplation of or intended to a) Age and state of health of the decedent at the time of gift, especially
take effect in possession or enjoyment at or after death,
where he was aware of the serious illness;
b) transfer by trust or otherwise, with retention or reservation of:
b) Length of time between the gift and the date of death. A short
(i) the possession or enjoyment of, or the right to the income interval suggest the conclusion that the thought of death was in the
from the property (ii) the right, either alone or in conjunction
decedent’s mind, and long interval suggests the opposite;
with any person, to designate the person who shall possess or
enjoy the property or the income therefrom. c) Concurrent making of a will or making a will within a short time
after the transfer
c) Exception: in case of bona fide sale for an adequate and full
consideration in money or money's worth.

ATTY. MARVIN P. CAN ERO, CPA 11 ATTY. MARVIN P. CAN ERO, CPA 12

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1. BAR: A, aged 90 years and suffering from incurable cancer, on August 1, C. Revocable Transfers
2001 wrote a will and, on the same day, made several inter-vivos gifts to
his children. Ten days later, he died. In your opinion, are the inter-vivos Ø These are transfers (except in case of a bona fide sale for an
gifts considered transfers in contemplation of death for purposes of adequate and full consideration in money or money's worth) by
determining properties to be included in his gross estate? trust or otherwise, where the enjoyment thereof was subject at the
date of his death to any change through the exercise of a power (in
2. BAR: Mr. Agustin, 75 years old and suffering from an incurable disease, whatever capacity exerciseable) by the decedent alone or by the
decided to sell for valuable and sufficient consideration a house and lot decedent in conjunction with any other person (without regard to
to his son. He died one year later. In the settlement of Mr. Agustin's when or from what source the decedent acquired such power), to
estate, the BIR argued that the house and lot were transferred in alter, amend, revoke, or terminate, or where any such power is
contemplation of death and should therefore form part of the gross relinquished in contemplation of the decedent's death.
estate for estate tax purposes. Is the BIR correct?

ATTY. MARVIN P. CAN ERO, CPA 13 ATTY. MARVIN P. CAN ERO, CPA 14

D. Property Passing Under General Power of Appointment.

BAR: Mr. Mayuga donated his residential house and lot to his son and duly ØPower of appointment is the right to designate the person or persons
paid the donor's tax. In the Deed of Donation, Mr. Mayuga expressly who shall succeed to the property of the prior decedent.
reserved for himself the usufruct over the property for as long as he lived.
ØIt is general when the donee has been authorized to appoint any
Describe the donated property from the taxation perspective. person he pleases, including himself, thus having full-dominion over
the property as though he owned it.
ØIt is special when the donee can appoint only among restricted or a
designated class or persons other than himself.

ATTY. MARVIN P. CAN ERO, CPA 15 ATTY. MARVIN P. CAN ERO, CPA 16

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E. Proceeds of Life Insurance

• X executed a last will and testament designating Y as the successor to the 1) policy must be taken out by the decedent upon his life;
real property owned by X with right to designate the person or persons 2) If the beneficiary is the estate of the deceased, his executor, or
who shall succeed to the property. Upon the death of X, should the administrator, whether or not there is power of revocation;
property be included in the gross estate of X? if Y died thereafter, should 3) If the beneficiary is third person, the designation of the
the property be included in his gross estate? Explain beneficiary must be revocable, that is, when the designation of
the beneficiary is not expressly made irrevocable (if silent,
revocable)

ATTY. MARVIN P. CAN ERO, CPA 17 ATTY. MARVIN P. CAN ERO, CPA 18

ALLOWABLE DEDUCTIONS:
Residents and Citizens Non-Resident Aliens
F. Prior Interests 1. Claims against the estate 1. Proportion of the “CCULT” which
2. Claims against insolvent persons the value of such part bears to the
value of entire GE wherever
G. Transfers of Insufficient Consideration 3. Unpaid mortgages, taxes and situated: claims vs. the estate;
casualty losses claims vs. insolvent persons; and
Ø excess of the fair market value over the value of the consideration
received by the decedent. [Section 85(G), NIRC] 4. Property previously taxed unpaid mortgages, taxes and
5. Transfer for public used casualty losses
6. Family home (not exceeding 10M) 2. Property previously taxed
7. Standard deduction ( 5 Million) 3. Transfer for public used
8. Amount received under RA 4917 4. Standard deduction ( 5OO,000)
9. Net share of the surviving spouse 5. Net share of the surviving spouse
ATTY. MARVIN P. CAN ERO, CPA 19 ATTY. MARVIN P. CAN ERO, CPA 20

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A. Claims Against the Estate 5) Substantiation requirements :

1) The liability represe nts a personal obligation of the deceased existing at a. Simple Loan
the time of his death; i. The debt instrument must be notarized;
2) The liability was contracted in good faith and for adequate and full ii. Duly notarized certification of from the creditors as to the unpaid
consideration in money or money's worth; balance of the debt, including interest as of the time of death;
3) The claim must be a debt or claim which is valid in law and iii. Proof of financial capacity of the creditor to lend the amount at
enforceable in court; the time the loan was contracted
4) The indebtedness must not have been condoned by the creditor or iv. A statement under oath executed by the administrator or
executor of the estate reflecting the disposition of the proceeds of
the action to collect from the decedent must not have prescribed.
the loan if said loan was contracted within 3 years prior to the
death of the decedent

ATTY. MARVIN P. CAN ERO, CPA 21 ATTY. MARVIN P. CAN ERO, CPA 22

b. Unpaid obligation from purchase of goods or services Dizon vs. CTA, G.R. No. 140944, 30 April 2008

i. Pertinent documents evidencing the purchase of goods or ØThe claims existing at the time of death should be made the basis of
services the determination of allowable deductions. First. There is no law,
nor do we discern any legislative intent in our tax laws, which
ii. Duly notarized certification of from the creditors as to the
disregard the date-of-death valuation principle and particularly
unpaid balance of the debt, including interest as of the time of provide that post-death developments must be considered in
death; determining the net value of the estate. Second. Such construction
iii. Latest audited balance sheet of the creditor with a detailed finds relevance and consistency in our Rules on Special Proceedings
schedule of its receivable showing the unpaid balance of the wherein the term "claims" required to be presented against a
decedent-debtor with the updated subsidiary ledger/records decedent's estate is generally construed to mean debts or demands
of the debt. of a pecuniary nature which could have been enforced against the
deceased in his lifetime, or liability contracted by the deceased
before his death.

ATTY. MARVIN P. CAN ERO, CPA 23 ATTY. MARVIN P. CAN ERO, CPA 24

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D. Unpaid Taxes
B. Claims of the deceased against insolvent persons Øaccrued and unpaid as of the time of death.
ØThe value of the decedent's interest therein must be first included in Øexcluding income tax upon income received after death, or property
the value of the gross estate taxes not accrued before his death, or the estate tax due from the
transmission estate
C. Unpaid Mortgages E. Casualty Losses
1) The value of the property to the extent of the decedent's interest 1) incurred during the settlement of the estate
therein, undiminished by such mortgage or indebtedness, must be 2) arising from fires, storms, shipwreck, or other casualties, or from
included in the value of the gross estate; robbery, theft or embezzlement
2) The indebtedness must have been contracted bona fide and for an 3) not compensated for by insurance or otherwise
adequate and full consideration in money or money's worth. 4) Not claimed as a deduction for income tax purposes
5) incurred not later than the last day for the payment of the estate tax

ATTY. MARVIN P. CAN ERO, CPA 25 ATTY. MARVIN P. CAN ERO, CPA 26

F. Property Previously Taxed

1) Death – the present decedent died within 5 years from transfer of BAR: In 1999, Xavier purchased from his friend, Yuri, a painting for
the property from a prior decedent; P500,000.00. The fair market value (FMV) of the painting at the time of
2) Inclusion of the property the purchase was P1-million.Yuri paid all the corresponding taxes on
3) Previous taxation of the property the transaction. In 2001, Xavier died. In his last will and testament,
4) Identity of the property Xavier bequeathed the painting, already worth P1.5-million, to his only
5) No previous vanishing deduction on the property son, Zandro. The will also granted Zandro the power to appoint his wife,
Wilma, as successor to the painting in the event of Zandro's death.
Zandro died in2007, and Wilma succeeded to the property May a
vanishing deduction be allowed in either or both of the estates? Explain.

ATTY. MARVIN P. CAN ERO, CPA 27 ATTY. MARVIN P. CAN ERO, CPA 28

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G. Transfer for Public Use

ØThe disposition must be in the last will and testament which shall
take effect after death.
BAR: While driving his car to Baguio last month, Pedro Asuncion, together H. Family Home
with his wife Assunta, and only son, Jaime, met an accident that caused that 1) Actual residential home of the decedent and his family at the time of
instantaneous death of Jaime. The following day, Assunta also died in the his death, as certified by the Barangay Captain of the locality where
hospital. Is vanishing deduction applicable to the Estate of Assunta the family home is situated;
Asuncion? Explain 2) The total value of the family home must be included as part of the
. gross estate of the decedent; and
3) Allowable deduction is the current fair market value of the family
home as declared or included in the gross estate, or the extent of the
decedent's interest (whether conjugal/community or exclusive
property), whichever is lower, but not exceeding 10 MILLION PESOS

ATTY. MARVIN P. CAN ERO, CPA 29 ATTY. MARVIN P. CAN ERO, CPA 30

Exemption of Certain Acquisitions and Transmissions

I. Standard Deduction
Øadditional deduction without need of substantiation A. The merger of usufruct in the owner of the naked title;
Ø5 Million pesos for citizen or resident decedents B. The transmission or delivery of the inheritance or legacy by the
ØP500,000.00 for non-resident aliens fiduciary heir or legatee to the fideicommissary;
C. The transmission from the first heir, legatee or donee in favor of
J. Amount received by heirs under Republic Act No. 4917 another beneficiary, in accordance with the desire of the predecessor;
Øthe amount of the separation benefit must be included as part of the and
gross estate of the decedent D. All bequests, devises, legacies or transfers to social welfare, cultural
and charitable institutions:
K. Net share of the surviving spouse in the conjugal partnership or 1) no part of the net income shall insure to the benefit of any
community property individual
Øto ensure that only the decedent's interest in the estate is taxed 2) not more than 30% of the said bequests, devises, legacies or
transfers shall be used for administration purposes.
ATTY. MARVIN P. CAN ERO, CPA 31 ATTY. MARVIN P. CAN ERO, CPA 32

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Valuation of the Gross Estate

A. The properties shall be valued based on FMV as of the time of death; FILING OF ESTATE TAX RETURN
B. The FMV of real property is the FMV as determined by the CIR or the
FMV per schedule of values fixed by the assessor, whichever is higher;
C. The FMV of unlisted common shares are based on book value while A. Filingis required in; (a) all cases of transfers subject to estate tax; or,
unlisted preferred shares are valued at par value; (b) regardless of the gross value of the estate, where the said estate
D. The FMV of shares listed in the stock exchanges shall be the arithmetic consists of registered or registrable property;
mean between the highest and lowest quotation at a date nearest the B. If the gross value exceeds 5 MILLION Pesos, the return shall be
date of death, if none is available on the date of death; supported with a statement duly certified to by a CPA;
E. The FMV for units of participation in any association, recreation or
amusement club shall be the bid price nearest to the date of death; C. Filing shall be made within one year from the decedent's death;
F. For the right to usufruct, use or habitation, as well as that of annuity, the D. The CIR may grant, in meritorious cases, a reasonable extension, not
probable life of the beneficiary in accordance with the latest basic exceeding 30 days for filing the return
standard mortality table shall be taken into account .

ATTY. MARVIN P. CAN ERO, CPA 33 ATTY. MARVIN P. CAN ERO, CPA 34

PAYMENT OF ESTATE TAX

A. As a general rule, estate tax sha ll be paid at the time the return is filed by Payment by Installment
the executor, administrator or the heirs;
B. Extension of time to pay estate tax: when the payment of the estate tax or of
any part thereof would impose undue hardship upon the estate or any of Ø In case the available cash of the estate is insufficient to pay the
the heirs: (a) 5 years in case the estate is judicially settled; (b) 2 years in total estate tax due, payment by installment shall be allowed within
case the estate is settled extra-judicially; CIR may require the posting of 2 years from the statutory date for its payment without civil
bond in such amount, not exceeding double the amount of the tax and with penalty and interest.
such sureties as the CIR deems necessary, conditione d upon the payment Ø Filing should sti ll b e mad e within one year from dec edent’s
of the said tax;
death
C. Where the re que st for extension is by reason of neglige nce, intentional
disregard of rule s and regulations, or fraud on the part of the taxpayer, no Ø If the 2 year period has lapsed without the payment of the entire tax
extension will be granted; due, the remaining balance shall be due and demandable subject to
the applicable penalties and interest reckoned from the prescribed
deadline for filing the return and payment of the estate tax.
ATTY. MARVIN P. CAN ERO, CPA 35 ATTY. MARVIN P. CAN ERO, CPA 36

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Partial Disposition of Estate

Liability for Payment of Estate Tax
a) Estate tax return shall be filed within one year from decedent’s death;
b) File a written request for partial disposition with the BIR, together
with a notarized undertaking that the proceeds shall be exclusively ØThe executor or administrator of an estate has the primary
used for the payment of the total estate tax due; obligation to pay the estate tax.
c) The estate shall pay to the BIR the proportionate estate tax due of the ØWhere there are two or more executors or administrators, all of
property intended to be disposed of. them are severally liable for the payment of the tax.
d) In case of failure to pay the total estate tax due out from the proceeds ØThe heir or beneficiary, however, has subsidiary liability for the
of the disposition, the estate tax due shall be due and demandable payment of that portion of the estate which his distributive share
bears to the value of the total net estate. The extent of his liability
subject to the applicable penalties and interest reckoned from the shall in no case exceed the value of his share in the inheritance.
prescribed deadline for filing the return and payment of the estate
tax.
ATTY. MARVIN P. CAN ERO, CPA 37 ATTY. MARVIN P. CAN ERO, CPA 38

Provisions Safeguarding the Interest of the Government in the

Collection of Estate Taxes:

Ø If a bank has knowledge of the death of a person, who

maintained a bank deposit account alone, or jointly with
another, it shall allow any withdrawal from the said deposit
account, subject to a final withholding tax of 6%. DONOR’S TAX
ü The amounts withdrawn from the deposit accounts of a
decedent subjected to the 6% withholding tax imposed under
Section 97 of the NIRC shall be excluded from the gross estate
for purposes of computing the estate tax. ( RR 12-2018)

ATTY. MARVIN P. CAN ERO, CPA 39 ATTY. MARVIN P. CAN ERO, CPA 40

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Coverage and Imposition

CONCEPT AND NATURE

ØDonor’s tax is a tax on the privilege of transmitting one’s property or A. Donation of real and personal property, wherever situated, owned
property rights to another or others without adequate and full by resident or citizen at the time of donation;
valuable consideration.
B. Donation of real property and tangible personal property situated
ØIt is not a property tax but an excise tax imposed on the privilege of in the Philippines owned by non-resident alien at the time of
the owner to give. It is not a tax on the property as such because the donation;
imposition does not rest upon general ownership. ( Lladoc vs. CIR)
C. Donation of intangible personal property with a situs in the
ØThe law in force at the time of the perfection/completion of the Philippines owned by non-resident alien at the time of donation,
donation shall govern the imposition of donor’s tax. unless exempted on the basis of reciprocity.

ATTY. MARVIN P. CAN ERO, CPA 41 ATTY. MARVIN P. CAN ERO, CPA 42

Indirect Donations Subject to Donor’s Tax

A. Condonation of Indebtedness
BAR: Miguel, a citizen and resident of Mexico, donated US$1,000.00 Ø If a creditor merely desires to benefit a debtor and without any
worth of stocks in Barack Motors Corporation, a Mexican company, to consideration therefor cancels the debt.
his legitimate son, Miguelito, who is residing in the Philippines and B. Renunciation of Inheritance
about to be married to a Filipino girlfriend. Mexico does not impose any Ø Renunciation by the surv iving spouse of his/ her sha re in the conjugal
transfer tax of whatever natureon all gratuitous transfers of property. Is partnership or absol ute community after the dissolution of the marriage
Miguel entitled to the rule of reciprocity in order to be exempt from the in favor of the heirs of the deceased spouse or any other person/s is
Philippine donor's tax? Why or why not? subject to donor's tax.
Ø General renunciation by an heir, including the surviving spouse, of
his/her share in the hereditary estate left by the decedent is not
subject to donor's tax, unless specifically and categorically done in
favor of identified heir/s to the exclusion or disadvantage of the
other co-heirs in the hereditary estate.
ATTY. MARVIN P. CAN ERO, CPA 43 ATTY. MARVIN P. CAN ERO, CPA 44

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C. Transfer for less than adequate and full consideration

BAR: In the settlement of the estate of Mr. Barbera who died intestate, ØWhere property, other than a real property that has been
his wife renounced her inheritance and her share of the conjugal subjected to the final capital gains tax, is transferred for less than
property in favor of their children. The BIR determined that there was an adequate and full consideration in money or money's worth, then
a taxable gift and thus assessed Mrs.Barbera as a donor. Was the BIR the amount by which thefair market value of the property at the time
correct? of sale exceeded the value of the agreed or actual consideration or
selling price shall be deemed a gift.
ØException: Sale, exchange, or other transfer of property made in the
ordinary course of business (a transaction which is a bona fide, at
arm’s length, and free from any donative intent).

ATTY. MARVIN P. CAN ERO, CPA 45 ATTY. MARVIN P. CAN ERO, CPA 46

RATE OF DONOR’S TAX Computation of the Donor's Tax

A.Donations shall be subject to donor’s tax applicable when the donations
are made;
ØThe tax for each calendar year shall be six percent (6%) computed
on the basis of the total gifts in excess of Two hundred fifty B.The computation is on a cumulative basis over a period of one calendar
thousand pesos (₱250,000) exempt gift made during the calendar year; the tax base shall be the net gift made during the calendar year;
year.

C.Husband and wife are considered as separate and distinct taxpayer's for
purposes of the donor's tax. However, if what was donated is a conjugal
or community property and only the husband signed the deed of
donation, there is only one donor for donor's tax purposes, without
prejudice to the right of the wife to question the validity of the donation
without her consent.
ATTY. MARVIN P. CAN ERO, CPA 47 ATTY. MARVIN P. CAN ERO, CPA 48

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Exemption of Certain Gifts

A. Gifts made to or for the use of the National Government or an entity

created by any of its agencies which is not conducted for profit, or to
any of its political subdivision; and BAR: The Congregation of the Mary Immaculate donated a land and a
dormitory building located along España St. in favor of the Sisters of the
B. Gifts in favor of an educational and/or charitable, religious, cultural Holy Cross, a group of nuns operating a free clinic and high school
or social welfare corporation, institution, accredited nongovernment teaching basic spiritual values. Is the donation subject to donor’s tax?
organization, trust or philanthropic organization or research Reason briefly.
institution or organization.
1) Not more than 30% of said gifts shall be used by such donee for
administration purposes;
2) Donee (except religious entity) is incorporated as a nonstock
entity, paying no dividends, governed by trustees who receive no
compensation, and devoting all its income to the accomplishment
and promotion of the purposes enumerated in its AOI.
ATTY. MARVIN P. CAN ERO, CPA 49 ATTY. MARVIN P. CAN ERO, CPA 50

Political Campaign Contributions

ØAny provision of law to the contrary notwithstanding any contribution in BAR: Mr. De Sarapen is a candidate in the upcoming Senatorial elections.
cash or in kind to any candidate or political party or coalition of parties Mr. De Almacen, believing in the sincerity and ability of Mr. De Sarapen to
for campaign purposes, duly reported to the COMELEC shall not be introduce much needed reforms in the country, contributed P500,000.00 in
subject to the payment of any gift tax. ( Section 13, RA 7166). cash to the campaign chest of Mr. De Sarapen. In addition, Mr. De Almacen
ØHowever, unutilized/excess campaign funds, that is, campaign purchased tarpaulins, t-shirts, umbrellas, caps and other campaign
contributions net of the candidate’s campaign expenditures shall be materials that he also donated to Mr. De Sarapen for usein his campaign. Is
considered as subject to income tax. the contribution of cash and campaign materials subject to donor’s tax?
ØIf the candidate – winning or losing- fails to file with the COMELEC the
appropriate statement of expenditures, he is precluded from claiming the
expenditures as deductions from his campaign contributions. As, such,
the entire campaign contribution shall be subject to income tax.

ATTY. MARVIN P. CAN ERO, CPA 51 ATTY. MARVIN P. CAN ERO, CPA 52

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Filing of Return and Payment of Tax

ØThe donor's tax return shall be filed within 30 days after the date the
gift is made or completed and the tax due thereon shall be paid at the THANK YOU!
same time that the return is filed.

ATTY. MARVIN P. CAN ERO, CPA 53 ATTY. MARVIN P. CAN ERO, CPA 54

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