Taxation Bar Qs

8/10/2019 Taxation Bar Qs

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1. This Questionnaire contains THIRTEEN (13) pagesincluding these Instructions pages. Check the number ofpages and the page numbers at the upper right handcorner of each page of this Questionnaire and makesure it has the correct number of pages and their propernumbers.

There are TWENTY-NINE (29) Essay and MultipleChoice Questions (MCQs) to be answered within four (4)

hours.

The essay portion contains questions that are equivalentto not lessthan 80% of the whole examination, while theMCQ portion contains questions equivalent to notmorethan 20%.

2. Read each question very carefully and write youranswers in your Bar Examination Notebook in the sameorder the questions are posed.Write your answers onlyon the front,not the back, page of every sheet in yourNotebook. Note well the allocated percentage points foreach number, question, or sub-question. In your

answers, use the numbering system in thequestionnaire.

If the sheets provided in your Examination Notebook arenot sufficient for your answers, use the back page ofevery sheet of your Examination Notebook, starting atthe back page of the first sheet and the back of thesucceeding sheets thereafter.

3. Answer the Essay questions legibly, clearly, andconcisely.Start each number on a separate page. Ananswer to a sub-question under the same number maybe written continuously on the same page and the

immediately succeeding pages until completed.

Your answer should demonstrate your ability to analyzethe facts presented by the question, to select thematerial from the immaterial facts, and to discern thepoints upon which the question turns. It should showyour knowledge and understanding of the pertinentprinciples and theories of law involved and theirqualifications and limitations. It should demonstrate yourability to apply the law to the given facts, and to reasonlogically in a lawyer-like manner to a sound conclusionfrom the given premises.

A mere "Yes" or "No" answer without any correspondingexplanation or discussion will not be given anycredit.Thus, always briefly but fully explain your answersalthough the question does not expressly ask for anexplanation. At the same time, remember that acomplete explanation does not require that you volunteerinformation or discuss legal doctrines that are notnecessary or pertinent to the solution to the problem.You do not need to re-write or repeat the question inyour Notebook.

4. MCQs are to be answered by writing in your Notebookthe capital letter A, B, C, D, or E corresponding to yourchosen answer. There is only one correct answer toevery MCQ; choose the BEST answer from among theoffered choices. Note that some MCQs may need carefuanalysis both of the questions and the choices offered.

5. Make sure you do not write your name or anyextraneous note/sor distinctive marking/son your

Notebook that can serve as an identifying mark/s (suchas names that are not in the given questions, prayers, orprivate notes to the Examiner).

Writing, leaving or making any distinguishing oridentifying mark in the exam Notebook is consideredcheating and can disqualify you for the Barexaminations.

You can use the questionnaire for notes you maywish/need to write during the examination.

YOU CAN BRING HOME THIS QUESTIONNAIRE OR

HAND IT TOGETHER WITH YOUR NOTEBOOK

J. DIOSDADO M. PERALTAChairman

2014 Bar Examinations

I.

On March 27, 2012, the Bureau of Internal Revenue(BIR) issued a notice of assessment against Blue WaterIndustries Inc. (BWI), a domestic corporation, informingthe latter of its alleged deficiency corporate income taxfor the year 2009. On April 20, 2012, BWI filed a letterprotest before the BIR contesting said assessment anddemanding that the same be cancelled or set aside.

However, on May 19, 2013, that is, after more than ayear from the filing of the letter protest, the BIR informedBWI that the latters letter protest was denied on theground that the assessment had already become final,executory and demandable. The BIR reasoned that itsfailure to decide the case within 180 days from filing ofthe letter protest should have prompted BWI to seekrecourse before the Court of Tax Appeals (CTA) by filinga petition for review within thirty (30) days after theexpiration of the 180-day period as mandated by the

provisions of the last paragraph of Section 228 of theNational Internal Revenue Code (NIRC). Accordingly,BWIs failure to file a petition for review before the CTArendered the assessment final, executory anddemandable. Is the contention of the BIR correct?Explain. (5%)

II.

Mr. De Sarapen is a candidate in the upcomingSenatorial elections. Mr. De Almacen, believing in thesincerity and ability of Mr. De Sarapen to introduce much


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needed reforms in the country, contributed P500,000.00in cash to the campaign chest of Mr. De Sarapen. Inaddition, Mr. De Almacen purchased tarpaulins, t-shirts,umbrellas, caps and other campaign materials that healso donated to Mr. De Sarapen for use in his campaign.Is the contribution of cash and campaign materialssubject to donors tax? (4%)

III.

Dr. Taimtim is an alumnus of the College of Medicine ofUniversal University (UU), a privately-owned center forlearning which grants yearly dividends to itsstockholders.

UU has a famous chapel located within the campuswhere the old folks used to say that anyone who wantedto pass the medical board examinations should offer adozen roses on all the Sundays of October. This waswhat Dr. Taimtim did when he was still reviewing for theboard examinations. In his case, the folk saying provedto be true because he is now a successful cardiologist.

Wanting to give back to the chapel and help defray thecosts of its maintenance, Dr. Taimtim donatedP50,000.00 to the caretakers of the chapel which wasevidenced by an acknowledgment receipt.

In computing his net taxable income, can Dr.Taimtim usehis donation to the chapel as an allowable deductionfrom his gross income under the National InternalRevenue Code (NIRC)? (4%)

IV.

Gangwam Corporation (GC) filed its quarterly tax returns

for the calendar year 2012 as follows:

First quarter - April 25, 2012

Second quarter - July 23, 2012

Third quarter - October 25, 2012

Fourth quarter - January 27, 2013

On December 22, 2013, GC filed with the Bureau ofInternal Revenue (BIR) an administrative claim for

refund of its unutilized input Value-Added Tax (VAT) forthe calendar year 2012. After several months of inactionby the BIR on its claim for refund, GC decided to elevateits claim directly to the Court of Tax Appeals (CTA) onApril 22, 2014.

In due time, the CTA denied the tax refund relative to theinput VAT of GC for the first quarter of 2012, reasoningthat the claim was filed beyond the two-year periodprescribed under Section 112(A) of the National InternalRevenue Code (NIRC).

(A) Is the CTA correct? (3%)

(B) Assuming that GC filed its claim before theCTA on February 22, 2014, would your answerbe the same? (3%)

V.

The City of Liwliwa assessed local business taxes

against Talin Company. Claiming that there is doubletaxation, Talin Company filed a Complaint for Refund orRecovery of Illegally and/or Erroneously-collected LocalBusiness Tax; Prohibition with Prayer to IssueTemporary Restraining Order and Writ of PreliminaryInjunction with the Regional Trial Court (RTC). The RTCdenied the application for a Writ of PreliminaryInjunction. Since its motion for reconsideration wasdenied, Talin Company filed a special civil action forcertiorari with the Court of Appeals (CA). Thegovernment lawyer representing the City of Liwliwaprayed for the dismissal of the petition on the groundthat the same should have been filed with the Court of

Tax Appeals (CTA). Talin Company, through its lawyer,Atty. Frank, countered that the CTA cannot entertain apetition for certiorari since it is not one of its powers andauthorities under existing laws and rules.

Decide. (5%)

VI.

Choose the correct answer. Smuggling - (1%)

(A) does not extend to the entry of imported orexported articles by means of any false or

fraudulent invoice, statement or practices; theentry of goods at less than the true weight ormeasure; or the filing of any false or fraudulententry for the payment of drawback or refund ofduties.

(B) is limited to the import of contraband orhighly dutiable cargo beyond the reach ofcustoms authorities.

(C) is committed by any person who shallfraudulently import or bring into the Philippines,or assist in so doing, any article, contrary to law,or shall receive, conceal, buy, sell or anymanner facilitate the transportation,concealment or sale of such article afterimportation, knowing the same to have beenimported contrary to law.

VII.

In accordance with the Local Government Code (LGC),the Sangguniang Panglungsod (SP) of Baguio Cityenacted Tax Ordinance No. 19, Series of 2014, imposinga P50.00 tax on all the tourists and travellers going to


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(1) Family home in Makati City;

(2) Condominium unit in Las Pias City;

(3) Proceeds of health insurance from TakeCare, a health maintenance organization in thePhilippines; and

(4) Land in Alabama, U.S.A.

The following expenses were paid:

(1) Funeral expenses;

(2) Medical expenses; and

(3) Judicial expenses in the testate proceedings.

(A) What are the items that must be consideredas part of the gross estate income of Mr. X?

(B) What are the items that may be consideredas deductions from the gross estate?

XV.

When is a pre-assessment notice required under thefollowing cases? (1%)

(A) When the finding for any deficiency tax is theresult of mathematical error in the computationof the tax as appearing on the face of the return.

(B) When a discrepancy has been determinedbetween the tax withheld and the amountactually remitted by the withholding agent.

(C) When the excise tax due on excisablearticles has been paid.

(D) When an article locally purchased orimported by an exempt person, such as, but notlimited to vehicles, capital equipment,machineries and spare parts, has been sold,traded or transferred to non-exempt persons.

XVI.

Mr. Tiaga has been a law-abiding citizen diligentlypaying his income taxes. On May 5, 2014, he wassurprised to receive an assessment notice from theBureau of Internal Revenue (BIR) informing him of adeficiency tax assessment as a result of a mathematicalerror in the computation of his income tax, as appearingon the face of his income tax return for the year 2011,which he filed on April 15, 2012. Mr. Tiaga believes thatthere was no such error in the computation of his incometax for the year 2011. Based on the assessment

received by Mr. Tiaga, may he already file a protestthereon? (4%)

XVII.

In a civil case for Annulment of Contract of Sale, plaintiffMa. Reklamo presented in evidence the Contract of Salewhich she sought to be annulled. No documentary stamptax on the Contract of Sale was paid because according

to plaintiff Ma. Reklamo, there was no need to pay thesame since the sale was not registered with the Registerof Deeds. Plaintiff Ma. Reklamo is now offering theContract of Sale as her evidence. Is the Contract of Saleadmissible? (4%)

XVIII.

Madam X owns real property in Caloocan City. On July1, 2014, she received a notice of assessment from theCity Assessor, informing her of a deficiency tax on herproperty. She wants to contest the assessment. (4%)

(A) What are the administrative remediesavailable to Madam X in order to contest theassessment and their respective prescriptiveperiods?

(B) May Madam X refuse to pay the deficiencytax assessment during the pendency of herappeal?

XIX.

The Bureau of Internal Revenue (BIR) issued RevenueMemorandum Circular (RMC) No. 65-2012 imposingValue-Added Tax (VAT) on association dues andmembership fees collected by condominiumcorporations from its member condominium-unit owners.The RMCs validity is challenged before the SupremeCourt (SC) by the condominium corporations.

The Solicitor General, counsel for BIR, claims thatassociation dues, membership fees, and otherassessment/charges collected by a condominiumcorporation are subject to VAT since they constituteincome payments or compensation for the beneficialservices it provides to its members and tenants.

On the other hand, the lawyer of the condominiumcorporations argues that such dues and fees are merelyheld in trust by the condominium corporationsexclusively for their members and used solely foradministrative expenses in implementing thecondominium corporations purposes. Accordingly, thecondominium corporations do not actually renderservices for a fee subject to VAT.

Whose argument is correct? Decide. (5%)

XX.


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(3) Representation expenses incurred inmeetings with clients

(A) What are the items in the above mentionedearnings which should be included in thecomputation of ABC Law Firms gross income?Explain.

(B) What are the items in the above-mentioned

payments which may be considered asdeductions from the gross income of ABC LawFirm? Explain.

(C) If ABC Law Firm earns net income in 2012,what, if any, is the tax consequence on the partof ABC Law Firm insofar as the payment ofincome tax is concerned? What, if any, is the taxconsequence on the part of A, B, and C asindividual partners, insofar as the payment ofincome tax is concerned?

XXV.

Which of the following transactions is subject to Value-Added Tax (VAT)? (1%)

(A) Sale of shares of stock-listed and tradedthrough the local stock exchange

(B) Importation of personal and householdeffects belonging to residents of the Philippinesreturning from abroad subject to custom dutiesunder the Tariff and Customs Code

(C) Services rendered by individuals pursuant toan employeremployee relationship

(D) Gross receipts from lending activities bycredit or multi-purpose cooperatives dulyregistered with the Cooperative DevelopmentAuthority

XXVI.

Freezy Corporation, a domestic corporation engaged inthe manufacture and sale of ice cream, made paymentsto an officer of Frosty Corporation, a competitor in the

ice cream business, in exchange for said officersrevelation of Frosty Corporations trade secrets.

May Freezy Corporation claim the payment to the officeras deduction from its gross income? Explain. (4%)

XXVII.

In January 2013, your friend got his first job as an o fficeclerk. He is single and lives with his family who dependsupon him for financial support. His parents have longretired from their work, and his two (2) siblings are still

minors and studying in grade school. In February 2014,he consulted you as he wanted to comply with all therules pertaining to the preparation and filing of hisincome tax return. He now asks you the following:

(A) Is he entitled to personal exemptions? If so,how much? (1%)

(B) Is he entitled to additional exemptions? If so,

how much? (1%)

(C) What is the effect of the taxes withheld fromhis salaries on his taxable income? (2%)

XXVIII.

Choose the correct answer. Tax laws - (1%)

(A) may be enacted for the promotion of privateenterprise or business for as long as it givesincidental advantage to the public or the State

(B) are inherently legislative; therefore, may notbe delegated

(C) are territorial in nature; hence, they do notrecognize the generally-accepted tenets ofinternational law

(D) adhere to uniformity and equality when alltaxable articles or kinds of property of the sameclass are taxable at the same rate

XXIX.

Doa Evelina, a rich widow engaged in the business ofcurrency exchange, was assessed a considerableamount of local business taxes by the City Governmentof Bagnet by virtue of Tax Ordinance No. 24. Despite herobjections thereto, Doa Evelina paid the taxes.Nevertheless, unsatisfied with said Tax Ordinance, DoaEvelina, through her counsel Atty. ELP, filed a writtenclaim for recovery of said local business taxes andcontested the assessment. Her claim was denied, andso Atty. ELP elevated her case to the Regional TrialCourt (RTC).

The RTC declared Tax Ordinance No. 24 null and voidand without legal effect for having been enacted inviolation of the public ation requirement of taxordinances and revenue measures under the LocalGovernment Code (LGC) and on the ground of doubletaxation. On appeal, the Court of Tax Appeals (CTA)affirmed the decision of the RTC. No motion forreconsideration was filed and the decision became finaland executory. (4%)


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(A) If you are Atty. ELP, what advice will yougive Doa Evelina so that she can recover thesubject local business taxes?

(B) If Doa Evelina eventually recovers the localbusiness taxes, must the same be consideredas income taxable by the national government?

ESSAY QUESTIONS

I.

In its final adjustment return for the 2010 taxable year,ABC Corp. had excess tax credits arising from its over-withholding of income payments. It opted to carry overthe excess tax credits to the following year.Subsequently, ABC Corp. changed its mind and appliedfor a refund of the excess tax credits.

Will the claim for refund prosper? (6%)

II.

A group of philanthropists organized a non-stock, non-profit hospital for charitable purposes to provide medicalservices to the poor. The hospital also accepted payingpatients although none of its income accrued to anyprivate individual; all income were plowed back for thehospital's use and not more than 30% of its funds wereused for administrative purposes.

Is the hospital subject to tax on its income? If it is, atwhat rate? (6%)

III.

ABC Corporation is registered as a holding companyand has an office in the City of Makati. It has no actualbusiness operations. It invested in another company andits earnings are limited to dividends from this investment,interests on its bank deposits, and foreign exchangegains from its foreign currency account. The City ofMakati assessed ABC Corporation as a contractor orone that sells services for a fee. Is the City of Makaticorrect? (6%)

IV.

Atty. Gambino is a partner in a general professionalpartnership. The partnership computes its grossrevenues, claims deductions allowed under the TaxCode, and distributes the net income to the partners,including Atty. Gambino, in accordance with its articlesof partnership.

In filing his own income tax return, Atty. Gambinoclaimed deductions that the partnership did not claim,such as purchase of law books, entertainment expenses,

car insurance and car depreciation. The BIR disallowedthe deductions.

Was the BIR correct? (6%)

V.

Mr. Agustin, 75 years old and suffering from an incurabledisease, decided to sell for valuable and sufficient

consideration a house and lot to his son. He died oneyear later.

In the settlement of Mr. Agustin's estate, the BIR arguedthat the house and lot were transferred in contemplationof death and should therefore form part of the grossestate for estate tax purposes.

Is the BIR correct? (7%)

VI.

On October 15, 2005, ABC Corp. imported 1,000 kilos ofsteel ingots and paid customs duties and VAT to theBureau of Customs on the importation. On February 17,2009, the Bureau of Customs, citing provisions of theTariff and Customs Code on post-audit, investigated andassessed ABC Corp. for deficiency customs duties andVAT.

Is the Bureau of Customs correct? (7%)

VII.

XYZ Law Offices, a law partnership in the Philippines

and a VAT-registered taxpayer, received a query by e-mail from Gainsburg Corporation, a corporationorganized under the laws of Delaware, but the e-mailcame from California where Gainsburg has an office.Gainsburg has no office in the Philippines and does nobusiness in the Philippines.

XYZ Law Offices rendered its opinion on the query andbilled Gainsburg US$1,000 for the opinion. Gainsburgremitted its payment through Citibank which convertedthe remitted US$1 ,000 to pesos and deposited theconverted amount in the XYZ Law Offices account.

What are the tax implications of the payment to XYZ LawOffices in terms of VAT and income taxes? (7%)

VIII.

Mr. Amado leased a piece of land owned by theMunicipality of Pinagsabitan and built a warehouse onthe property for his business operations. The MunicipalAssessor assessed Mr. Amado for real property taxes onthe land and the warehouse. Mr. Amado objected to theassessment, contending that he should not be asked to


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pay realty taxes on the land since it is municipalproperty.

Was the assessment proper? (5%)

IX.

In the settlement of the estate of Mr. Barbera who diedintestate, his wife renounced her inheritance and her

share of the conjugal property in favor of their children.The BIR determined that there was a taxable gift andthus assessed Mrs. Barbera as a donor.

Was the BIR correct? (7%)

X.

In 2010, pursuant to a Letter of Authority (LA) issued bythe Regional Director, Mr. Abcede was assesseddeficiency income taxes by the BIR for the year 2009.He paid the deficiency. In 2011, Mr. Abcede receivedanother LA for the same year 2009, this time from theNational Investigation Division, on the ground that Mr.Abcede's 2009 return was fraudulent.

Mr. Abcede contested the LA on the ground that he canonly be investigated once in a taxable year. Decide.(7%)

XI.

In 2000, Mr. Belen bought a residential house and lotfor P1,000,000. He used the property as his and hisfamily's principal residence. It is now year 2013 and he

is thinking of selling the property to buy a new one. Heseeks your advice on how much income tax he wouldpay if he sells the property. The total zonal value of theproperty is P5,000,000 and the fair market value per thetax declaration is P2,500,000. He intends to sell itforP6,000,000.

What material considerations will you take into accountin computing the income tax? Please explain the legalrelevance of each of these considerations. (7%)

XII.

You are the retained tax counsel of ABC Corp. Yourclient informed you that they have been directlyapproached with a proposal by a BIR insider (i.e., amiddle rank BIR official) on the tax matter they havereferred to you for handling. The BIR insider's proposalis to settle the matter by significantly reducing theassessment, but he will get 50% of the savings arisingfrom the reduced assessment.

What tax, criminal and ethical considerations will youtake into account in giving your advice? Explain therelevance of each of these considerations. (9%)

MULTIPLE CHOICE QUESTIONS

I. ABC Corp. was dissolved and liquidating dividendswere declared and paid to the stockholders.

What tax consequence follows? (1%)

(A) ABC Corp. should deduct a final tax of 10%from the dividends.

(B) The stockholders should declare their gainfrom their investment and pay income tax at theordinary rates.

(C) The dividends are exempt from tax.

(D) ABC Corp. should withhold a 10% creditabletax.

II. MGC Corp. secured an income tax holiday for 5 yearsas a pioneer industry. On the fourth year of the tax

holiday, MGC Corp. declared and paid cash dividends toits stockholders, all of whom are individuals.

Are the dividends taxable? (1%)

(A) The dividends are taxable; the tax exemptionof MGC Corp. does not extend to itsstockholders.

(B) The dividends are tax exempt because ofMGC Corp.'s income tax holiday.

(C) The dividends are taxable if they exceed

50% of MGC Corp.'s retained earnings.

(D) The dividends are exempt if paid before theend of MGC Corp.'s fiscal year.

III. Mr. Alas sells shoes in Makati through a retail store.He pays the VAT on his gross sales to the BIR and themunicipal license tax based on the same gross sales tothe City of Makati. He comes to you for advice becausehe thinks he is being subjected to double taxation.

What advice will you give him? (1%)

(A) Yes, there is double taxation and it isoppressive.

(B) The City of Makati does not have this power.

(C) Yes, there is double taxation and this isillegal m the Philippines.

(D) Double taxation is allowed where one tax isimposed by the national government and theother by the local government.


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IV. Congress passed a sin tax law that increased the taxrates on cigarettes by 1,000%. The law was thought tobe sufficient to drive many cigarette companies out ofbusiness, and was questioned in court by a cigarettecompany that would go out of business because it wouldnot be able to pay the increased tax.

The cigarette company is __________ (1%)

(A) wrong because taxes are the lifeblood of thegovernment

(B) wrong because the law recognizes that thepower to tax is the power to destroy

(C) correct because no government can deprivea person of his livelihood

(D) correct because Congress, in this case,exceeded its power to tax

V. Mr. Alvarez is in the retail business. He received adeficiency tax assessment from the BIR containing onlythe computation of the deficiency tax and the penalties,without any explanation of the factual and legal bases forthe assessment.

Is the assessment valid? (1%)

(A) The assessment is valid; all that Mr. Alvarezhas to know is the amount of the tax.

(B) The assessment is invalid; the law requires astatement of the facts and the law upon which

the assessment is based.

(C) The assessment is valid but Mr. Alvarez canstill contest it.

(D) The assessment is invalid because Mr.Alvarez has no way to determine if thecomputation is erroneous.

VI. In 2010, Mr. Platon sent his sister Helen $1 ,000 viaa telegraphic transfer through the Bank of PI. The bank'sremittance clerk made a mistake and credited Helen with$1,000,000 which she promptly withdrew. The bank

demanded the return of the mistakenly credited excess,but Helen refused. The BIR entered the picture andinvestigated Helen.

Would the BIR be correct if it determines that Helenearned taxable income under these facts? (1%)

(A) No, she had no income because she had noright to the mistakenly credited funds.

(B) Yes, income is income regardless of thesource.

(C) No, it was not her fault that the funds inexcess of $1,000 were credited to her.

(D) No, the funds in excess of$1,000 were ineffect donated to her.

VII. The municipality of San Isidro passed an ordinanceimposing a tax on installation managers. At that time,there was only one installation manager in the

municipality; thus, only he would be liable for the tax.

Is the law constitutional? (1%)

(A) It is unconstitutional because it clearlydiscriminates against this person.

(B) It is unconstitutional for lack of legal basis.

(C) It is constitutional as it applies to all personsin that class.

(D) It is constitutional because the power to taxis the power to destroy.

VIII. XYZ Corporation manufactures glass panels and isalmost at the point of insolvency. It has no more cashand all it has are unsold glass panels. It received anassessment from the BIR for deficiency income taxes. Itwants to pay but due to lack of cash, it seeks permissionto pay in kind with glass panels.

Should the BIR grant the requested permission? (1%)

(A) It should grant permission to make payment

convenient to taxpayers.

(B) It should not grant permission because a taxis generally a pecuniary burden.

(C) It should grant permission; otherwise, XYZCorporation would not be able to pay.

(D) It should not grant permission because thegovernment does not have the storage facilitiesfor glass panels.

IX. Prior to the VAT law, sales of cars were subject to asales tax but the tax applied only to the original or thefirst sale; the second and subsequent sales were notsubject to tax.

Deltoid Motors, Inc. (Deltoid) hit on the idea of setting upa wholly-owned subsidiary, Gonmad Motors, Inc.(Gonmad), and of selling its assembled cars to Gonmadat a low price so it would pay a lower tax on the firstsale. Gonmad would then sell the cars to the public at ahigher price without paying any sales tax on thissubsequent sale.


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Characterize the arrangement. (1%)

A. The plan is a legitimate exercise of taxplanning and merely takes advantage of aloophole in the law.

B. The plan is legal because the governmentcollects taxes anyway.

C. The plan is improper; the veil of corporatefiction can be pierced so that the second salewill be considered the taxable sale.

D. The government must respect Gonmad'sseparate juridical personality and Deltoid'staxable sale to it.

X. PRT Corp. purchased a residential house and lot witha swimming pool in an upscale subdivision and requiredthe company president to stay there without paying rent;it reasoned out that the company president mustmaintain a certain image and be able to entertain guests

at the house to promote the company's business. Thecompany president declared that because they arechildless, he and his wife could very well live in a smallerhouse.

Was there a taxable fringe benefit? (1%)

(A) There was no taxable fringe benefit since itwas for the convenience of the employer andwas necessary for its business.

(B) There was a taxable fringe benefit since thestay at the house was for free.

(C) There was a taxable fringe benefit becausethe house was very luxurious.

(D) There was no taxable fringe benefit becausethe company president was only required to staythere and did not demand free housing.

XI. Taxpayer A was required by the BIR to sign andsubmit a waiver of the statute of limitations on theassessment period, to give the BIR more time tocomplete its investigation. The BIR accepted the waiver

but failed to indicate the date of its acceptance.

What is the legal status of the waiver? (1%)

(A) The waiver is valid because the date ofacceptance is immaterial and unimportant.

(B) The waiver is invalid; the taxpayer cannot berequired to waive the statute of limitations.

(C) The waiver is invalid; the date of acceptanceis crucial in counting the start of the period ofsuspension of the prescriptive period.

(D) The waiver is valid, having been accepted bythe BIR.

XII. Taxpayer Andy received on January 3, 2010 apreliminary assessment notice (PAN) from the BIR,

stating that he had fifteen (15) days from its receipt tocomment or to file a protest. Eight (8) days later (or onJanuary11, 2010), before he could comment or file aprotest, Andy received the final assessment notice(FAN).

Decide on the validity of the FAN. (1%)

(A) The FAN is invalid; Andy was not given thechance to respond to the PAN, in violation of hisdue process rights.

(B) The FAN is invalid for being premature.

(C) The FAN is valid since it was issued beforethe right to assess prescribed.

(D) The FAN is valid. There is no legalrequirement that the FAN should await theprotest to the PAN because protest to the PANis not mandatory.

XIII. MSI Corp. imports orange and lemon concentratesas raw materials for the fruit drinks it sells locally. TheBureau of Customs (BOC) imposed a 1% duty rate onthe concentrates. Subsequently, the BOC changed itsposition and held that the concentrates should be taxedat 7% duty rate. MSI disagreed with the ruling andquestioned it in the CTA which upheld MSI's position.The Commissioner of Customs appealed to the CTA enbane without filing a motion for reconsideration.

Resolve the appeal. (1%)

(A) The appeal should be dismissed because amotion for reconsideration is mandatory.

(B) The appeal should be dismissed for having

been filed out of time.

(C) The appeal should be given due coursesince a motion for reconsideration is a uselessexercise.

(D) The appeal should be upheld to be fair to thegovernment which needs taxes.

XIV. The spouses Jun and Elvira Sandoval purchased apiece of land for P5,000,000 and included their two (2)minor children as co-purchasers in the Deed of Absolute


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Sale. The Commissioner of Internal Revenue (CIR) ruledthat there was an implied donation and assesseddonors' taxes against the spouses.

Rule on the CIR's action. (1%)

(A) The CIR is wrong; a donation must beexpress.

(B) The CIR is wrong; financial capacity is not arequirement for a valid sale.

(C) The CIR is correct; the amount involved ishuge and ultimately ends up with the children.

(D) The CIR is correct; there was animusdonandi since the children had no financialcapacity to be co-purchasers.

XV. Pheleco is a power generation and distributioncompany operating mainly from the City of Taguig. Itowns electric poles which it also rents out to othercompanies that use poles such as telephone and cablecompanies. Taguig passed an ordinance imposing a feeequivalent to 1% of the annual rental for these poles.Pheleco questioned 'the legality of the ordinance on theground that it imposes an income tax which localgovernment units (LGUs) are prohibited from imposing.

Rule on the validity of the ordinance. (1%)

(A) The ordinance is void; the fee is based onrental income and is therefore a tax on income.

(B) The ordinance is valid as a legitimateexercise of police power to regulate electricpoles.

(C) The ordinance is void; 1% of annual rental isexcessive and oppressive.

(D) The ordinance is valid; an LGU may imposea tax on income.

XVI. Aleta sued Boboy for breach of promise to marry.Boboy lost the case and duly paid the court's award thatincluded, among others, Pl00,000 as moral damages for

the mental anguish Aleta suffered.

Did Aleta earn a taxable income? (1%)

(A) She had a taxable income of P100,000 sinceincome is income from whatever source.

(B) She had no taxable income because it was adonation.

(C) She had taxable income since she made aprofit.

(D) She had no taxable income since moraldamages are compensatory.

XVII. Mr. Mayuga donated his residential house and lotto his son and duly paid the donor's tax. In the Deed ofDonation, Mr. Mayuga expressly reserved for himself theusufruct over the property for as long as he lived.

Describe the donated property from the taxation

perspective. (1%)

(A) The property will form part of Mr. Mayuga'sgross estate when he dies.

(B) The property will not fom1 part of Mr.Mayuga's gross estate when he dies because hepaid the donor's tax.

(C) The property will form part of Mr. Mayuga'sgross estate because he died soon after thedonation.

(D) The property will not form part of Mr.Mayuga's gross estate because it is no longerhis.

XVIII. Mr. Z made an importation which he declared atthe Bureau of Customs (BOC) as "Used TruckReplacement Parts". Upon investigation, the containervans contained 15 units of Porsche and Ferrari cars.

Characterize Mr. Z's action. (1%)

(A) Mr. Z committed smuggling.

(B) Mr. Z did not commit smuggling because hesubmitted his shipment to BOC examination.

(C) Mr. Z only made a misdeclaration, but didnot commit smuggling.

(D) Mr. Z did not commit smuggling because theshipment has not left the customs area.

XIX. Mr. A was preparing his income tax return and hadsome doubt on whether a commission he earned shouldbe declared for the current year or for the succeedingyear. He sought the opinion of his lawyer who advisedhim to report the commission in the succeeding year. Heheeded his lawyer's advice and reported the commissionin the succeeding year. The lawyer's advice turned outto be wrong; in Mr. A's petition against the BIRassessment, the court ruled against Mr. A.

Is Mr. A guilty of fraud? (1%)

(A) Mr. A is not guilty of fraud as he simplyfollowed the advice of his lawyer.


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(B) Mr. A is guilty of fraud; he deliberately didnot report the commission in the current yearwhen he should have done so.

(C) Mr. A's lawyer should pay the tax for givingthe wrong advice.

(D) Mr. A is guilty for failing to consult hisaccountant.

XX. The BIR, through the Commissioner, instituted asystem requiring taxpayers to submit to the BIR asummary list of their sales and purchases during theyear, indicating the name of the seller or the buyer andthe amount. Based on these lists, the BIR discoveredthat in 2004 ABC Corp. purchased from XYZ Corp.goods worthP5,000,000. XYZ Corp. did not declarethese for income tax purposes as its reported grosssales for 2004was only Pl,000,000.

Which of the following defenses may XYZ Corp.interpose in an assessment against it by the BIR? (1%)

(A) The BIR has no authority to obtain third partyinformation to assess taxpayers.

(B) The third party information is inadmissible ashearsay evidence.

(C) The system of requiring taxpayers to submitthird party information is illegal for violating theright to privacy.

(D) None of the above.

1. Bank A deposit money with Bank B which earnsinterest that is subjected to the 20% final withholding tax.At the same time, Bank A is subjected to the 5% grossreceipts tax on its interest income on loan transactions tocustomers. Which statementbelow INCORRECTLY describes the transaction?

a) There is double taxation because two taxes income tax and gross receipts tax are imposedon the interest incomes described above anddouble taxation is prohibited under the 1987Constitution

b) There is no double taxation because the firsttax is income tax, while the second tax isbusiness tax;

c) There is no double taxation because theincome tax is on the interest income of Bank Aon its deposits with Bank B (passive income),while the gross receipts tax is on the interestincome received by Bank A from loans to itsdebtor-customers (active income);

d) Income tax on interest income of deposits ofBank A is a direct tax, while GRT on interestincome on loan transaction is an tax.

2. Which of the following statement is NOT correct?

a) In case of doubt, statutes levying taxes areconstructed strictly the government;

b) The construction of a statute made by hispredecessors is not binding upon the successor,if thereafter he becomes satisfied that a differentconstruction should be given;

c) The reversal of a ruling shall not generally begiven retroactive application, if said reversal willbe prejudicial to the taxpayer;

d) A memorandum circular promulgated by theCIR that imposes penalty for violations of certainrules need not be published in a newspaper ofgeneral circulation or official gazette because it

has the force and effect of law.

3. Which statement below expresses the lifebloodtheory?

a) The assessed taxes must be enforced by thegovernment.

b) The underlying basis of taxation isgovernment necessity, for without taxation, agovernment can neither exist nor endure;

c) Taxation is an arbitrary method of exaction bythose who are in the seat of power;

d) The power of taxation is an inherent power ofthe sovereign to impose burdens upon subjectsand objects within its jurisdiction for the purposeof raising revenues.

4. Which statement is WRONG?

a) The power of taxation may be exercised bythe government, its political subdivisions, andpublic utilities;

b) Generally, there is no limit on the amount oftax that may be imposed;

c) The money contributed as tax becomes partof the public funds;

d) The power of tax is subject to certainconstitutional limitations.

5. The Philippines adopted the semi-global tax system,which means that:


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a) All taxable incomes, regardless of the natureof income, are added together to arrive at grossincome, and all allowable deductions arededucted from the gross income to arrive at thetaxable income;

b) All incomes subject to final withholding taxesliable to income tax under the schedular taxsystem, while all ordinary income as well as

income not subject to final withholding tax underthe global tax system;

c) All taxable incomes are subject to finalwithholding taxes under the schedular taxsystem;

d) All taxable incomes from sources within andwithout the Philippines are liable to income tax.

6. Income from the performance of services is treated asincome from within the Philippines, if:

a) The payment of compensation for the serviceis made in the Philippines;

b) The contract calling for the performance ofservices is signed in the Philippines;

c) The service is actually performed in thePhilippines;

d) The recipient of service income is a residentof the Philippines.

7. For income tax purposes, the source of the serviceincome is important for the taxpayer, who is a:

a) Filipino citizen residing in Makati City;

b) Non-resident Filipino citizen working residingin London, United Kingdom;

c) Japanese citizen who is married to a Filipinocitizen and residing in their family home locatedFort Bonifacio, Taguig City;

d) Domestic corporation.

8. Interest income of a domestic commercial bankderived from a peso loan to a domestic corporation in2010 is :

a) Subject to the 30% income tax based on itsnet taxable income;

b) Subject to the 20% final withholding tax;

c) Subject to the 7.5% final withholding tax;

d) Subject to 10% final withholding tax.

9. A resident corporation is one that is:

a) Organized under the laws of the Philippinesthat does business in another country;

b) Organized under the laws of a foreign countrythat sets up a regional headquarter in the

Philippines doing product promotion andinformation dissemination;

c) Organized under the laws of the Philippinesthat engages business in a special economiczone;

d) Organized under the laws of a foreign countrythat engages in business in Makati City,Pihlippines.

10. A dealer in securities sold unlisted shares of stocksof a domestic corporation in 2010 and derived a gain ofP1 Million therefrom. The gain is:

a) Taxable at 30% regular corporate income taxbased on net taxable income;

b) Taxable at 5%/10% capital gains tax basedon net capital gain;

c) Taxable at of 1% stock transaction taxbased on the gross selling price or fair marketvalue, whichever is higher

d) Exempt from income tax

11. An individual, who is a real estate dealer, sold aresidential lot in Quezon City at a gain of P100,000.00(selling price of P900,000.00 and cost is P800,00.00).The sale is subject to income tax as follows:

a) 6% capital gains tax on the gain;

b) 6% capital gains tax on the gross selling priceof fair market value, whichever is higher;

c) Ordinary income tax at the graduated rates of5% to 32% of net taxable income;

d) 30% income tax on net taxable income.

12. During the audit conducted by the BIR official, it wasfound that the rental income claimed by the corporationwas not subjected to expanded withholding tax.Accordingly, the claimed rental expense:


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a) Is deductible from the gross income of thecorporation, despite non-withholding of incometax by the corporation;

b) Is deductible from the gross income of thecorporation, provided that the 5% expandedwithholding tax is paid by the corporation duringthe audit;

c) Is not deductible from gross income of thecorporation due to non-withholding of tax;

d) Is deductible, if it can be shown that thelessor has correctly reported the rental incomein his tax return.

13. A resident Filipino citizen (not a dealer in securities)sold shares of stocks of a domestic corporation that arelisted and traded in the Philippine Stock Exchange.

a) The sale is exempt from income tax butsubject to the of 1% stock transaction tax;

b) The sale is subject to income tax computed atthe graduated income tax rates of 5% to 32% onnet taxable income;

c) The sale is subject to the stock transaction taxand income tax;

d) The sale is both exempt from the stocktransaction tax and income tax.

14. The appropriate method of accounting for a

contractor on his long-term construction contract (i.e., ittakes more than a year to finish) is:

a) Cash method;

b) Accrual method;

c) Installment sale method;

d) Percentage of completion method.

15. A general professional partnership (GPP) is one:

a) That is registered as such with the Securitiesand Exchange Commission and the Bureau ofInternal Revenue;

b) That is composed of individuals who exercisea common profession;

c) That exclusively derives income from thepractice of the common profession;

d) That derives professional income and rentalincome from property owned by it.

16. The interest expense of a domestic corporation on abank loan in connection with the purchase of aproduction equipment:

a) Is not deductible from gross income of theborrower-corporation;

b) Is deductible from the gross income of theborrower-corporation during the year or it maybe capitalized as part of cost of the equipment;

c) Is deductible only for a period of five yearsfrom date of purchase;

d) Is deductible only if the taxpayer uses thecash method of accounting.

17. The "all events test" refers to:

a) A person who uses the cash method whereall sales have been fully paid by the buyersthereof;

b) A person who uses the installment salesmethod, where the full amount of considerationis paid in full by the buyer thereof within the yearof sale;

c) A person who uses the accrual method,whereby an expense is deductible for thetaxable year in which all the events had

occurred which determined the fact of theliability and the amount thereof could bedetermined with reasonable accuracy;

d) A person who uses the completed method,whereby the construction project has beencompleted during the year the contract wassigned.

18. All the items below are excluded from gross income,except:

a) Gain from sale of long-term bonds,

debentures and indebtedness;

b) Value of property received by a person asdonation or inheritance;

c) Retirement benefits received from the GSIS,SSS, or accredited retirement plan;

d) Separation pay received by a retiringemployee under a voluntary retirement programof the corporate employer.


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19. Which statement is correct? A non-stock, non-profitcharitable association that sells its idle agriculturalproperty is:

a) Not required to file an income tax return norpay income tax on the transaction to the BIR,provided the sales proceeds are invested inanother real estate during the year;

b) Required to pay the 6% capital gains tax onthe gross selling price of fair market value,whichever is higher;

c) Mandated to pay the 30% regular corporateincome tax on the gain from sale;

d) Required to withhold the applicable expandedwithholding tax rate on the transaction and remitthe same to the BIR.

20. ABS Corporation is a PEZA-registered exportenterprise which manufactures cameras and sells all its

finished products abroad. Which statementis NOT correct?

a) ABS Corporation is subject to the 5% final taxon gross income earned, in lieu of all nationaland local taxes;

b) ABS Corporation is exempt from the 30%corporate income tax on net income, provided itpays value added tax;

c) ABS Corporation is subject to the 30%corporate income tax on net income;

d) ABS Corporation is exempt from all nationaland local taxes, except real property tax.

21. In May 2010, Mr. And Mrs. Melencio Antoniodonated a house and lot with a fair market value of P10Million to their sob, Roberto, who is to be married duringthe same year to Josefina Angeles. Which statementbelow isINCORRECT?

a) There are four (4) donations madetwo (2)donations are made by Mr. Melencio Antonio to

Roberto and Josefina, and two (2) donations aremade by Mrs. Antonio;

b) The four (4) donations are made by theSpouses Antonio to members of the family,hence, subject to the graduated donors taxrates (2%-15%);

c) Two (2) donations are made by the spousesto members of the family, while two (2) otherdonations are made to strangers;

d) Two (2) donations made by the spouses toRoberto are entitled to deduction from the grossgift as donationproper nuptias.

22. While he was traveling with friends, Mr. JoseFrancisco, resident Filipino citizen, died on January 20,2011 in a California Hospital, USA, leaving personal andreal properties with market values as follows: House andLot in Quezon CityP10 Million; Cash in bank in

CaliforniaUS$10,000.00; Citibank in New YorkUS$5,000.00; Cash in BPI MakatiP4 Million; Car inQuezon CityP1 Million; Shares of stocks of AppleCorporation, US corporation listed in NY StockExchangeUS$1 = Php50. His gross estate for thePhilippine estate tax purposes shall be:

a) P13 Million;

b) P14 Million;

c) P15 Million;

d) P16 Million.

23. In 2006, Mr. Vicente Tagle, a retiree, bought 10,000CDA shares that are unlisted in the local stock exchangefor P10 per share. In 2010, the said shares had a bookvalue per share of P60 per share. In view of a caraccident in 2010, Mr. Vicente Tagle had to sell his CDAshares but he could sell the same only for P50 pershare. The sale is subject to tax as follos:

a) 5%/10% capital gains tax on the capital gainfrom sale of P40 per share (P50 selling priceless P10 cost);

b) 5%/10% capital gains tax on the capital gainof P50 per share, arrived at by deducting thecost (P10 per share) from the book value (P60per share);

c) 5%/10% capital gains tax on the capital gainfrom sale of P40 per share (P50 selling priceless P10 cost) plus donors tax on the excess ofthe fair market value of the shares over theconsideration;

d) Graduated income tax rates of 5% to 32% onthe net taxable income from the sale of theshares.

24. On January 10, 2011, Maria Reyes, single-mother,donated cash in the amount of P50,000.00 to herdaughter Cristina, and on December 20, 2011, shedonated another P50,000.00 to Cristina. Whichstatement is correct?

a) Maria Reyes is subject to donors tax in 2011because gross gift is P100,000.00;


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b) Maria Reyes is exempt from donors tax in2011 because gross gift is P100,000.00;

c) Maria Reyes is exempt from donors tax in2011 only to the extent of P50,000.00;

d) Maria Reyes is exempt from donors tax in2011 because the donee is minor.

25. Jose Ramos, single, died of a heart attack onOctober 10, 2011, leaving a residential house and lotwith a market value of P1.8 Million and cash ofP100,000.00. Funeral expenses paid amounted toP250,000.00

a) His estate will be exempt from estate taxbecause the net estate is zero;

b) His estate will be subject to estate taxbecause net estate is P1,650,000.00;

c) His estate will be subject to estate taxbecause net estate is P1,700,00.00;

d) His estate will be subject to estate taxbecause net estate is P800,000.00.

26. Sale of residential house and lot by an official of adomestic corporation to another official in the samecorporation for a consideration of P2.5 Million in 2011 is:

a) Exempt from VAT because the gross sales donot exceed P2.5 Million;

b) Exempt from VAT because the property soldis a capital asset, regardless of the gross sellingprice;

c) Exempt from VAT because the seller is not aperson engaged in real estate business;

d) Taxable at 12% VAT output tax on the grossselling price of P2.5 Million.

27. An importer of flowers from abroad in 2011:

a) Is liable for VAT, if it registers as a VATperson;

b) Is exempt from VAT, because the goods aretreated as agricultural products;

c) Is exempt from VAT, provided that his totalimportation of flowers does not exceed P1.5Million;

d) Is liable for VAT, despite the fact that it did noregister as a VAT person and its total annualsales of flowers do not exceed P1.5 Million.

28. A VAT-registered contractor performed services forhis customer in 2010 and billed him P11.2 Million,broken down as follows: P10 Millioncost of services,plus P1.2 Million, 12% VAT. Of the contract price of P10Million, only P8 Million plus VAT thereon was received

from the customer in 2010, and the balance of P4 Millionplus VAT was received by the contractor in 2011. Howmuch is the taxable gross receipts of the contractor for2010, for VAT purposes?

a) P10 Million, the total cost of servicesperformed in 2010;

b) P8 Million, the amount received from thecustomer in 2010;

c) P8 Million plus VAT received from thecustomer in 2010;

d) P11.2 Million, the total cost of servicesperformed plus 12% VAT.

29. MBM Corporation is the owner-operator of moviehouses in Cavite. During the year 2010, it received atotal gross receipts of P20 Million from the operation ofmovies. It did not register as a VAT person. Whichstatement below is correct?

a) MBM Corporation is exempt from the 12%VAT, but liable for the 20% amusement tax onadmissions under the Local Government Code;

b) MBM Corporation is both liable for the 12%VAT and 20% amusement tax on admissions;

c) MBM Corporation is both exempt from the12% VAT and 20% amusement tax onadmissions;

d) MBM Corporation is liable for the 12% VAT,but exempt from the 20% amusement tax onadmissions.

30. A pawnshop shall now be treated, for business taxpurposes:

a) As a lending investor liable to the 12% VATon its gross receipts from interest income andfrom gross selling price from sale of unclaimedproperties;

b) Not as a lending investor, but liable to the 5%gross receipts tax imposed on a non-bankfinancial intermediary under Title VI (OtherPercentage Taxes);


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c) As exempt from 12% VAT and 5% grossreceipts tax;

d) As liable to the 12% VAT and 5% grossreceipts tax.

31. Under the VAT system, there is no cascadingbecause the tax itself is not again being taxed. However,in determining the tax base on sale of taxable goods

under the VAT system:

a) The professional tax paid by the professionalis included in gross receipts;

b) The other percentage tax (e.g., gross receiptstax) paid by the taxpayer is included in grossselling price;

c) The excise tax paid by the taxpayer beforewithdrawal of the goods from the place ofproduction or from customs custody is includedin the gross selling price;

d) The documentary stamp tax paid by thetaxpayer is included in the gross selling price orgross receipts.

32. Except for one transaction, the rest are exempt fromvalue added tax. Which one is VAT taxable?

a) Sales of chicken by a restaurant owner whodid not register as a VAT person and whosegross annual sales is P1.2 Million;

b) Sales of copra by a copra dealer to a coconutoil manufacturer who did not register as a VATperson and whose gross annual sales is P5Million;

c) Gross receipts of CPA during the yearamounted to P1 Million; the CPA registered as aVAT person in January 2011, before practicinghis profession;

d) Sales of a book store during the yearamounted to P10 Million; it did not register as aVAT person with the BIR.

33. A lessor or real property is exempt from value addedtax in one of the transactions below. Which one is it?

a) Lessor leases commercial stalls located in theGreenhills Commercial Center to VAT-registeredsellers of cell phones; lessors gross rentalduring the year amounted to P12 Million;

b) Lessor leases residential apartment units toindividual tenants for P10,000.00 per month per

unit; his gross rental income during the yearamounted to P2 Million;

c) Lessor leases commercial stalls atP10,000.00 per stall per month and residentialunits at P15,000.00 per unit per month; his grossrental income during the year amounted to P3Million;

d) Lessor leases two (2) residential houses andlots at P50,000.00 per month per unit, but heregistered as a VAT person.

34. IBP Bank extended loans to debtors during the year,with real properties of the debtors being used ascollateral to secure the loans. When the debtors failed topay the unpaid principal and interests after severaldemand letters, the bank foreclosed the same andentered into contracts of lease with tenants. The bank issubject to the tax as follows:

a) 12% VAT on the rental income, but exempt

from the 7% gross receipts tax;

b) 7% gross receipts tax on the rental income,but exempt from VAT;

c) Liable to both the 12% VAT and 7% grossreceipts tax;

d) Exempt from both the 12% VAT and 7%gross receipts tax.

35. Which transaction below is subject to VAT?

a) Sale of vegetables by a farmer in Baguio Cityto a vegetable dealer;

b) Sale of vegetables by a vegetable dealer inBaguio City to another vegetable dealer inQuezon City;

c) Sale of vegetables by the QC vegetabledealer to a restaurant in Manila;

d) Sale of vegetables by the restaurant operatorto its customers.

36. Which importation in 2011 is subject to VAT?

a) Importation of fuels by a person engaged ininternational shipping worth P20 Million;

b) Importation of raw, unprocessed, refrigeratedKobe beef from Japan by a beef dealer for saleto hotels in Makati City with a fair market valueof P10 Million;


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c) Importation of wines by a wine dealer with afair market value of P2 million for sale to hotelsin Makati City;

d) Importation of books worth P5 Million andschool supplies worth P1.2 million.

37. Input tax is available to a VAT-registered buyer,provided that:

a) The seller is a VAT-registered person;

b) The seller issues a VAT invoice or officialreceipt, which separately indicates the VATcomponent;

c) The goods or service is subject to or exemptfrom VAT, but the sale is covered by a VATinvoice or receipt issued by VAT-registeredperson;

d) The name and TIN of the buyer is not statedor shown in the VAT invoice or receipt

Which statement shown above is NOT correct?

38. Claim for tax credit or refund of excess input tax isavailable only to:

a) A VAT-registered person whose sales aremade to embassies of foreign governments andUnited Nations agencies located in thePhilippines without the BIR approval of theapplication for zero-rating;

b) Any person who has excess input tax arisingfrom local purchases of taxable goods andservices;

c) A VAT-registered person whose sales aremade to clients in the Philippines;

d) A VAT-registered person whose sales aremade to customers outside the Philippines andwho issued VAT invoices or receipts with thewords "ZERO RATED SALES" imprinted on thesales invoices or receipts.

39. A hotel operator that is a VAT-registered person andwho leases luxury vehicles to its hotel customers is:

a) Subject to the 3% common carriers tax and12% VAT;

b) Subject to the 3% common carriers tax only;

c) Subject to the 12% VAT only;

d) Exempt from both the 3% common carrierstax and 12% VAT.

40. Which statement is correct? A bar review centerowned and operated by lawyers is:

a) Exempt from VAT, regardless of its grossreceipts during the year because it is aneducational center;

b) Exempt from VAT, provided that its annualgross receipts do not exceed P1.5 Million in2011;

c) Subject to VAT, regardless of its grossreceipts during the year;

d) Subject to VAT, if it is duly accredited byTESDA.

41. For 2012, input tax is not available as a creditagainst the output tax of the buyer of taxable goods orservices during the quarter, if:

a) The VAT invoice or receipt of the seller isregistered with the BIR;

b) The VAT invoice or receipt of the seller doesnot separately indicate the gross selling price orgross receipts and the VAT component therein;

c) The VAT invoice or receipt is issued in thename of the VAT-registered buyer and his TIN isshown in said invoice or receipt;

d) The VAT invoice or receipt issued by theseller shows the Taxpayer Identification Numberplus the word "VAT" or "VAT registered person".

42. The public market vendor below, who is not a VAT-registered person is liable to VAT in 2010, if:

a) She sells raw chicken and meats and hergross sales during the year is P2 Million;

b) She sells vegetables and fruits in her stall andher gross sales during the year is P1 Million;

c) She sells canned goods, processed coconutoils, and cut flowers in her stall and her grosssales during the year is P2.5 Million;

d) She sells live fish, shrimps, and crabs and hergross sales during the year is P5 Million.

43. Which statement is FALSE under the VAT law?


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a) A VAT-registered person will be subject toVAT for his taxable transactions, regardless ofhis gross sales or receipts;

b) A person engaged in trade or business sellingtaxable goods or services must register as aVAT person, when his gross sales or receipts forthe year 2011 exceed P1.5 Million;

c) A person who issued a VAT-registeredinvoice or receipt for a VAT-exempt transactionis liable to the 12% VAT as a penalty for thewrong issuance thereof;

d) Once a doctor of medicine exercises hisprofession during the year, he needs to registeras a VAT person and to issue VAT receipts forprofessional fees received.

44. The Commissioner of Internal Revenuemay NOT inquire into the bank deposits of a taxpayer,except:

a) When the taxpayer files a fraudulent return;

b) When the taxpayer offers to compromise theassessed tax based on erroneous assessment;

c) When the taxpayer offers to compromise theassessed tax based on financial incapacity topay and he authorizes the Commissioner inwriting to look into his bank records;

d) When the taxpayer did not file his income taxreturn for the year.

45. The Commissioner of Internal Revenue issued a BIRruling to the effect that the transaction is liable to incometax and value added tax. Upon receipt of the ruling, ataxpayer does not agree thereto. What is his properremedy?

a) File a petition for review with the Court of TaxAppeals within thirty (30) days from receiptthereof;

b) File a motion for reconsideration with the

Commissioner of Internal Revenue;

c) File an appeal to the Secretary of Financewithin thirty (30) days from receipt thereof;

d) File an appeal to the Secretary of Justicewithin thirty (30) days from receipt thereof.

46. On April 15, 2011, the Commissioner of InternalRevenue mailed by registered mail the final assessmentnotice and the demand letter covering the calendar year

2007 with the QC Post Office. Which statement iscorrect?

a) The assessment notice is void because it wasmailed beyond the prescriptive period;

b) The assessment notice is void because it wasnot received by the taxpayer within the three-year period from the date of filing of the tax

return;

c) The assessment notice is void if the taxpayercan show that the same was received only afterone (1) month from date of mailing;

d) The assessment notice is valid even if thetaxpayer received the same after the three-yearperiod from the date of filing of the tax return.

47. A preliminary Assessment Notice (PAN)is NOT required to be issued by the BIR before issuing aFinal Assessment Notice (FAN) on one of the following

cases:

a) When a taxpayer does not pay the 2010deficiency income tax liability on or before July15 of the year;

b) When the finding for any deficiency tax is theresult of mathematical error in the computationof the tax as appearing on the face of the return;

c) When a discrepancy has been determinedbetween the value added tax paid and theamount due for the year;

d) When the amount of discrepancy shown inthe Letter Notice is not paid within thirty (30)days from date of receipt.

48. When a protest against the deficiency income taxassessment was denied by the BIR Regional Director ofQuezon City, the appeal to the Court of Tax Appealsmust be filed by a taxpayer:

a) If the amount of basic tax assessed isP100,000.00 or more;

b) If the amount of basic tax assessed isP300,000.00 or more;

c) If the amount of basic tax assessed isP500,000.00 or more;

d) If the amount of basic tax assessed is P1Million or more;

49. The taxpayer received an assessment notice on Apri15, 2011 and filed its request for reinvestigation against


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the assessment on April 30, 2011. Additionaldocumentary evidence in support of its protest wassubmitted by it on June 30, 2011. If no denial of theprotest was received by the taxpayer, when is the lastday for the filing of its appeal to the CTA?

a) November 30, 2011;

b) December 30, 2011;

c) January 30, 2012;

d) February 28, 2012.

50. Using the same facts in the immediately precedingnumber, but assuming that the final decision on thedisputed assessment was received by the taxpayer onJuly 30, 2011, when is the last day for filing of the appealto the CTA?

a) August 30, 2011;

b) September 30, 2011;

c) December 30, 2011;

d) January 30, 2012.

51. Which court has jurisdiction to determine if thewarrant of distraint and levy issued by the BIR is validand to rule if the waiver of the Statute of Limitations wasvalidly effected?

a) City Courts;

b) Regional Trial Court;

c) Court of Tax Appeals;

d) Court of Appeals.

52. Which statement below on compromise of tax liabilityis correct?

a) Compromise of a tax liability is available onlyat the administrative level;

b) Compromise of a tax liability is available onlybefore trial at the CTA;

c) Compromise of a tax liability is available evenduring appeal, provided that prior leave of courtis obtained;

d) Compromise of a tax liability is still availableeven after the court decision has become finaland executory.

53. In case of full or partial denial of the written claim forrefund or excess input tax directly attributable to zero-rated sales, or the failure on the part of theCommissioner to act on the application within 120 daysfrom the date of submission of complete documents, anappeal must be filed with the CTA:

a) Within thirty (30) days after filing theadministrative claim with the BIR;

b) Within sixty (60) days after filing theadministrative claim with the BIR;

c) Within one hundred twenty (120) days afterfiling the administrative claim with the BIR;

d) Within thirty (30) days from the receipt of thedecision denying the claim or after the expirationof the 120-day period.

54. The submission of the required documents withinsixty (60) days from the filing of the protest is available

only where:

a) The taxpayer previously filed a Motion forReconsideration with the BIR official;

b) The taxpayer previously filed a request forreconsideration with the BIR official;

c) The taxpayer previously filed a request forreinvestigation with the BIR official;

d) The taxpayer previously filed an extension to

file a protest with the BIR official.

55. The prescriptive period for the collection of thedeficiency tax assessment will be tolled:

a) If the taxpayer files a request forreconsideration with the Asst. Commissioner;

b) If the taxpayer files a request forreinvestigation that is approved by theCommissioner of Internal Revenue;

c) If the taxpayer changes his address in thePhilippines that is communicated to the BIRofficial;

d) If a warrant of levy is served upon thetaxpayers real property in Manila.

56. Which statement is correct? The collection of adeficiency tax assessment by distraint and levy:

a) May be repeated, if necessary, until the fullamount due, including all expenses, is collected;


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b) Must be done successively, first by distraintand then by levy;

c) Automatically covers the bank deposits of adelinquent taxpayer;

d) May be done only once during the taxableyear.

57. The prescriptive period to file a criminal action is:

a) Ten (10) years from the date of discovery ofthe commission of fraud or non-filing of taxreturn;

b) Five (5) years from the date of issuance of thefinal assessment notice;

c) Three (3) years from the filing of the annualtax return;

d) Five (5) years from the commission of theviolation of the law, and if the same be notknown at the time, from the discovery thereofand the institution of judicial proceedings for itsinvestigation and punishment.

58. The accuseds mere reliance on the representationsmade by his accountant, with deliberate refusal oravoidance to verify the contents of his tax return and toinquire on its authenticity constitutes:

a) Simple negligence;

b) Gross negligence;

c) Willful blindness;

d) Excusable negligence.

59. The acquittal of the accused in the criminal action forthe failure to file income tax return and failure to supplycorrect information will have the following consequence:

a) The CTA will automatically exempt theaccused from any civil liability;

b) The CTA will still hold the taxpayer liable fordeficiency income tax liability in all cases, sincepreponderance of evidence is merely requiredfor tax cases;

c) The CTA will impose civil or tax liability only ifthere was a final assessment notice issued bythe BIR against the accused in accordance withthe prescribed procedures for issuingassessments, which was presented during thetrial;

d) The CTA will impose civil or tax liability,provided that a computation of the tax liability ispresented during the trial.

60. X Corporation had excess income tax payment forthe year 2008, which it chose to carry over in 2009. Infiling its 2009 corporate income tax return, it signified itsintention (by checking the small box "refund" at thebottom of the return) to get a refund of the overpaid

amount in 2008. Can the refund be allowed or not, and ifdisallowed, does X Corporation lose the claimedamount?

a) X Corporation may not get the refundbecause the decision to carry over in 2008 wasirrevocable for that year, and it may not changethat decision in succeeding years;

b) X Corporation may not get the refund in 2009,but the amount being claimed as refund may beutilized in succeeding years until fully exhaustedbecause there is no prescriptive period for carry

over of excess income tax payments;

c) X Corporation may get the refund, providedthat it will no longer carry over such amount orutilize the same against its income tax liability inthe future;

d) X Corporation may file instead a claim of taxcredit, in lieu of refund.

61. Which statement is correct?

a) Legislative acts passed by the municipal

council in the exercise of its lawmaking authorityare denominated as resolutions and ordinances;

b) Legislative acts passed by the municipalcouncil in the exercise of its lawmaking authorityare denominated as resolutions;

c) Legislative acts passed by the municipalcouncil in the exercise of its lawmaking authorityare denominated as ordinances;

d) Both ordinances and resolutions are solemn

and formal acts.

62. Which of the following statements is NOT a test of avalid ordinance?

a) It must not contravene the Constitution or anystatute;

b) It must not be unfair or oppressive;

c) It must not be partial or discriminatory;


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d) It may prohibit or regulate trade.

63. Taxing power of local government unitsshall NOT extend to the following taxes, except one:

a) Income tax on banks and other financialinstitutions;

b) Taxes of any kind on the national

government, its agencies and instrumentalities,and local government units;

c) Taxes on agricultural and aquatic productswhen sold by the marginal farmers or fishermen;

d) Excise taxes on articles enumerated underthe National Internal Revenue Code.

64. Which statement on prescriptive periods is true?

a) The prescriptive periods to assess taxes in

the National Internal Revenue Code and theLocal Government Code are the same;

b) Local taxes shall be assessed within five (5)years from the date they became due;

c) Action for the collection of local taxes may beinstituted after the expiration of the period toassess and to collect the tax;

d) Local taxes may be assessed within ten (10)years from discovery of the underpayment of taxwhich does not constitute fraud.

65. The appraisal, assessment, levy and collection ofreal property tax shall be guided by the followingprinciples. Which statement does NOT belong here?

a) Real property shall be appraised at its currentand fair market value;

b) Real property shall be classified forassessment purposes on the basis of its actualuse;

c) Real property shall be assessed on the basisof a uniform classification within each localpolitical subdivision;

d) The appraisal and assessment of realproperty shall be based on audited financialstatements of the owner.

66. The Manila International Airport Authority (MIAA) isexempt from real property tax. Which statement belowisNOT correct?

a) MIAA is not a government-owned orcontrolled corporation because it is notorganized as a stock or non-stock corporation;

b) MIAA is a government instrumentality vestedwith corporate powers and performing essentialpublic services;

c) MIAA is not a taxable entity because the real

property is owned by the Republic of thePhilippines and the beneficial use of suchproperty has not been granted to a private entity

d) MIAA is a government-owned or controlledcorporation because it is required to meet thetest of economic viability.

67. For purposes of real property taxes, the tax rates areapplied on:

a) Zonal values;

b) Fair market value;

c) Assessed values;

d) Reproduction values.

68. One of the local government units belowdoes NOT have the power to impose real property tax:

a) Bacoor, Cavite;

b) Davao City;

c) Tarlac Province;

d) Malabon, Metro Manila.

69. Where the real property tax assessment iserroneous, the remedy of the property owner is:

a) To file a claim for refund in the Court of TaxAppeals if he has paid the tax, within thirty (30)days from date of payment;

b) To file an appeal with the Provincial Board ofAssessment Appeals within thirty (30) days fromreceipt of the assessment;

c) To file an appeal with the Provincial Board ofAssessment Appeals within sixty (60) days fromreceipt of the assessment;

d) To file an appeal with the Provincial Board ofAssessment Appeals within sixty (60) days fromreceipt of the assessment and playing theassessed tax under protest.


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70. The City Government of Manila may NOT impose:

a) Basic real property tax at 2% of the assessedvalue of real property;

b) Additional levy on real property for the specialeducation fund at 1% of the assessed value ofreal property;

c) Additional ad valorem tax on idle lands at arate not exceeding 5% of the assessed value;

d) Special levy on lands within its territoryspecially benefited by public works projects orimprovements funded by it at 80% of the actualcost of the projects or improvements.

71. Importation of goods is deemed terminated:

a) When the customs duties are paid, even if thegoods remain within the customs premises;

b) When the goods are released or withdrawnfrom the customs house upon payment of thecustoms duties or with legal permit to withdraw;

c) When the goods enter Philippines territoryand remain within the customs house withinthirty (30) days from date of entry;

d) When there is part payment of duties on theimported goods located in the customs area.

72. A protest against an assessment issued by the

Collector of Customs for unpaid customs duties onimported goods shall be filed with:

a) The Commissioner of Customs;

b) The Regional Trial Court;

c) The Court of Tax Appeals;

d) The Collector of Customs.

73. The dutiable value of an imported article subject to

an ad valoremrate of duty under existing law shall be:

a) The home consumption value;

b) The total value;

c) The total landed cost;

d) The transaction value.

74. The imported articles shall in any case be subject tothe regular physical examination when:

a) The importer disagrees with the findings ascontained in the government surveyors report;

b) The number, weight and nature of packagesindicated in the customs entry declaration andsupporting documents differ from that in themanifest;

c) The container is not leaking or damaged;

d) The shipment is covered by alert/hold ordersissued pursuant to an existing order.

75. Which cases are appealable to the CTA?

a) Decisions of the Secretary of Finance incases involving liability for customs duties,seizure, detention or release of propertyaffected;

b) Decisions of the Commissioner of Customs incases involving liability for customs duties,seizure, detention or release of propertyaffected;

c) Decisions of the Collector of Customs incases involving liability for customs duties,seizure, detention or release of propertyaffected;

d) Decisions of the BIR Commissioner in casesinvolving liability for customs duties, seizure,detention or release of property affected.

- NOTHING FOLLOWS -

HAND IN YOUR ANSWER SHEET.

THERE IS NO NEED TO RETURN THISQUESTIONNAIRE TO HEAD WATCHER.

2012 BAR EXAMINATIONSTAXATION LAW

14 October 2012 3:30 P.M.-5 P.M.

Set B

ESSAY TYPE QUESTIONSINSTRUCTIONS

The following questionnaire consists of ten (10)questions (numbered I to X) contained in SIX (6) pages.

Begin your answer to each numbered question on aseparate page; an answer to a sub-question/s under the


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same number maybe written continuously on the samepage and succeeding pages until completed.

Answer the question directly and concisely. Do notrepeat the question. Write legibly.

HAND IN YOUR NOTEBOOK. THERE IS NO NEED TORETURN THIS QUESTIONNAIRE TO THE HEADWATCHER.

GOODLUCK!!!

_____________________________________MARTIN S. VILLARAMA, JR.

Chairperson2012 Bar Examinations Committee

PLEASE CHECK THAT THIS SET CONTAINS SEVEN(7) PAGES (INCLUDING THIS PAGE).

WARNING: NOT FOR SALE OR UNAUTHORIZEDUSE

TAXATION LAW

I

Anchor Banking Corporation, which was organized in2000 and existing under the laws of the Philippines andowned by the Sy Family of Makati City, set up in 2010 abranch office in Shanghai City, China, to take advantageof the presence of many Filipino workers in that area andits booming economy. During the year, the bank

,management decided not to include the P20 Million netincome of the Shanghai Branch in the annual Philippineincome tax return filed with the BIR, which showed a nettaxable income of P30 Million , because the ShanghaiBranch is treated as a foreign corporation and is taxedonly on income from sources within the Philippines, andsince the loan and other business transactions weredone in Shanghai, these incomes are not taxable in thePhilippines.

a) Is the bank correct in excluding the netincome of its Shanghai Branch in thecomputation of its annual corporate income tax

for 2010? Explain your answer. (5%)

b) Should the Shanghai Branch of Anchor Bankremit profit to its Head Office in the Philippines in2011, is the branch liable to the 15% branchprofit remittance tax imposed under Section 28(A)(5) of the 1997 Tax Code? Explain youranswer (5%)

II

Foster Corporation (FC) is a Singapore-based foreigncorporation engaged in construction and installationprojects. In 2010, Global Oil Corporation (GOC), adomestic corpoartion engaged in the refinery ofpetroleum products, awarded an anti-pollution project toFoster Corporation, whereby FC shall design, supplymachinery and equipment, and install an anti-pollutiondevice for GOCs refinery in the Philippines, providedthat the installation part of the project may be sub-contracted to a local construction company. Pursuant tothe contract, the design and supply contracts were donein Singapore by FC, while the installation works weresub-contracted by the FC with the PhilippineConstruction Corporation (PCC), a domestic corporation.The project with a total cost of P100 Million wascompleted in 2011 at the following cost components:(designP20Million; machinery and equipmentP50Million; and installationP30 Million). Assume that theproject was 40% complete in 2010 and 100% completein 2011, based on the certificates issued by thecertificates issued by the architects and engineersworking on the project. GOC paid FC as follows: P60Million in 2010 and P40 Million in 2011, and FC paid

PCC ion foreign currency through a Philippine bank asfollows: P10 Million in 2010 and P20 Million in 2011.

a) Is FC liable to Philippines income tax, and ifso, how much revenue shall be reported by it in2010 and in 2011? Explain your answer. (5%)

b) Is PCC, which adopted the percentage ofcompletion method of reporting income andexpenses, liable to value added tax in 2010 andin 2011. Explain your answer. (5%)

III

Mr. Jose Castillo is a resident Filipino Citizen. Hepurchased a parcel of land in Makati City in 1970 at aconsideration of P1 Million. In 2011, the land , whichremained undeveloped and idle, had a fair market valueof P20Million. Mr. Antonio Ayala, another Filipino citizen,is very much interested in the property and he offered tobuy the same for P20 Million. The Assessor of MakatiCity re-assessed in 2011 the property at P10 Million.

a) When is Mr. Castillo liable for real propertytax on the land beginning 2011 or beginning

2012? Explain your answer. (2%)

b) Is Mr. Castillo liable for income tax in 2011based on the offer to buy by Mr. Ayala? Explainyour answer. (3%)

c) Should Mr. Castillo agree to sell the land toMr. Ayala in 2012 for P20 Million, subject to thecondition as stated in The Deed of Sale that thebuyer shall assume the capital gains taxthereon, how musch is the income tax due onthe transaction and when must the tax return be


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filed and the tax be paid by the taxpayer?Explain your answer. (5%)

IV

Mr. Pedro Aguirre, a resident citizen, is working for alarge real estate development company in the countryand in 2010, he was promoted to Vice-President of thecompany. With more responsibilities comes higher pay.

In 2011, he decided to buy a new car worth P2 Millionand he traded-in his old car with a market value ofP800,000.00 and paid the difference of P1.2 Million tothe car company. The old car, which was bought three(3) years ago by the father of Mr. Pedro Aguirre at priceof P700,000.00 was donated by him and registered inthe name of his son. The corresponding donors taxthereon was duly paid by the father.

a) How much is the cost basis of the old car toMr. Aguirre? Explain your answer (2%)

b) What is the nature of the old car capital

asset or ordinary asset? Explain your answer.(3%)

c) Is Mr. Aguirre liable to pay income tax on thegain from the sale of his old car? Explain youranswer. (5%)

V

Spouses Pablo Gonzales and Teresita Gonzales, bothresident citizens acquire during their marriage aresidential house and lot located in Makati City, which isbeing leased to a tenant for a monthly rental of

P100,000.00. Mr. Pablo Gonzales is the President of PGCorporation and he receives P50,000.00 salary permonth. The spouses have only one (1) minor child. Inlate June 2010, he was immediately brought to thehospital because of the heart attack and he waspronounced dead on June 30, 2010.With no liabilities,the estate of the late Pablo Gonzales was settled extra-judicially in early 2011.

a) Is Mr. Pablo Gonzales required to file incometax for 2010? If so, how much income must hedeclare for the year? How much personal andadditional exemption is he entitled to? Explain

your answer. (5%)

b) Is Mrs. Teresita Gonzales required to fileincome tax return fot 2010? If so, how muchincome must she declare for the year? Howmuch personal exemption is she entitled to?Explain your answer. (5%)

c) Is the Estate of the late Pablo Gonzalesrequired to file income tax return for 2010? If so,how much income must it declare for the year?

How much personal exemption is it entitled to?Explain your answer. (5%)

VI

The BIR issude in 2010 a final assessment notice anddemand letter against X Corporation covering deficiencyincome tas for the year 2008 in the amount of P10Million. X Corporation earlier requested the advice of a

lawyer on whether or not it should file a request forreconsideration or a request for reinvestigation. Thelawyer said it does not matter wheteher the protest filesagainst the assessment is a request for reconsiderationor a request for reinvestigation, because it has sameconsequences or implications.

a) What are the differences between a requestfor reconsideration and a request forreinvestigation? (5%)

b) Do you agree with the advice of the lawyer?Explain your answer (5%)

VII

a) May the bank depositspeso and foreign currency ofthe an individual taxpayer be disclosed by a commercialbank to the Commissioner of Internal Revenue, inconnection with a tax investigation being conducted byrevenue officials, without violating the relevant banksecrecy laws? Explain your answer. (5%)

b) In 2011, the Commissioner of the U.S. InternalRevenue Service (IRS) requested in writing theCommissioner of Internal Reveneu to get the

informatrion from a bank in the Philippines, regarding thedeposits of a U.S. Citizen residing in the Philippines,who is under examiniation by the officials of the US IRS,pursuant to the US-Philippine Tax Treaty and othertexisting laws. Should the BIR Commissioner agree toobtain such informarion from the bank and provide thesame to the IRS? Explain your answer. (5%)

c) Is the bank secrecy lawq in the Philippines violatedwhen the BIR issues a Warrant of Garnishment directedagainst a domestic bank, requiring it not to allow anywithdrawal from any existing bank deposit of hedelinquent taxpayer mentioned in the Warrant and to

freeze the same until the tax delinquency of saidtaxpayer is settled with the BIR? Explain your answer.(5%)

VIII

In the examination conducted by the revenue officialsagainst the corporate taxpayer in 2010, the BIR issued afinal assessment notice and demand letter which states:"It is requested that the above deficiency tax be paidimmediately upon receipt hereof, inclusive of penaltiesincident to delinquency. This is our final decision based


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on investigation. If you disagree, you may appeal thisfinal decision within thirty (30) days from receipt hereof,otherwise said deficiency tax assessment shall becomefinal, executory and demandable." The assessment wasimmediately appealed by the taxpayer to the Court ofTax Appeals, without filing its protest against theassessment and without a denial thereof by the BIR. Ifyou were the judge, would your deny the petition forreview filed by the taxpayer and consider the case asprematurely filed? Explain your answer (5%)

IX

On April 16, 2012, the corporation filed its annualcorporate income tax return for 2011, showing anoverpayment of income tax of P1 Million. Which is to becarried over to

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