June 21, 2010
BIR RULING [DA-(I-010) 103-10]
24 (D) (1); BIR Ruling [DA-(I-002) 011-08]; BIR Ruling No. 027-93
Reyes-Fajardo & Associates
Unit 1004-B Summit Tower One
530 Shaw Boulevard
Mandaluyong City
Attention: Attys. Marian Ivy F. Reyes-Fajardo
and
Maria Cecilia V. Soria
Gentlemen :
This refers to your letter dated June 04, 2009 requesting on behalf of your clients Spouses Danny and Florentina Siongco ("Spouses Siongco") and Ralph Lim Joseph ("Mr. Joseph"), successor-in-interest of Nacor Trading Incorporated ("NACOR") for exemption from the payment of capital gains tax and documentary stamp tax on the swapping of real properties to correct a mistake and without consideration. CETDHA
Background Facts:
Spouses Siongco are part owners with Jennifer Pua Dee-Chang of a parcel of land located in Tagaytay City (hereinafter "Lot A"). Lot A, which measures a total area of One Thousand square meters (1,000 sq.m.), and is covered by Transfer Certificate of Title (TCT) No. T-22091 issued in the name of Florentina Siongco and Jennifer Pua Dee.
Mr. Joseph is the successor-in-interest of a parcel of land adjacent to Lot A. This parcel of land also has a total area...