Atty. Elmer Distor

June 9, 2020BIR RULING NO. OT-309-20Sections 24 (D) (1) and 196 of the National Internal Revenue Code of 1997,as amended; BIR Ruling No. 224-11 dated July 12, 2011;BIR Ruling No. 252-13 dated July 8, 2013Atty. Elmer DistorAssistant SecretaryField Operations OfficeDepartment of Agriculture Sir :This refers to your letter dated February 21, 2020, requesting for a tax exemption on the transfer of parcels of land ("property") from MRC Allied Industries Incorporated ("MRC") to the Province of Leyte through a Deed of Forfeiture.It is represented that MRC bought the aforesaid property from AAA. For failure to pay the Province of Leyte the corresponding real property taxes from 2003 to 2008, MRC was declared delinquent. Consequently, the Province of Leyte issued a Warrant of Levy and Notice of Levy to MRC and the property was advertised for sale at a public auction. However, due to the lack of a bidder, the property was forfeited in favor of the Province of Leyte. HTcADCIn reply, please be informed that Section 263 of R.A. 7160 or the Local Government Code of...