May 4, 2010
BIR RULING [DA-(JV-015) 060-10]
Section 22 (B); BIR Ruling No. 018-99;
UN-141-94; UN-125-95; DA-064-96; DA-065-97; DA-488-98
Grand Monaco Estate Developers, Inc.
No. 6 Pittsburgh St., near Aurora Blvd.
Cubao, Quezon City
Attention: Mr. Reynaldo A. Carpio
President
Gentlemen :
This refers to your letter dated January 4, 2010 requesting for a ruling relative to the following: aSTHDc
1. Exemption of the Joint Venture Partnership from income tax under Section 27, in relation to Section 22 (b) of the Tax Code of 1997, and the relevant provisions of the President Decree (PD) 929;
2. Exemption of the assignment of Alicia Bello Baclig and Abelardo Baclig of its real estate property to Grand Monaco Estate Developers, Inc. from corporate income tax, creditable withholding tax, capital gain tax and documentary stamp tax, it being merely a transaction to effect its capital contribution to the joint venture partnership and not a taxable event;
3. Exemption of the Partition Agreement between Grand Monaco Estate Developers, Inc. (Developer) and Alicia Bello Baclig and Abelardo Baclig (Landowner) whereby the parties agreed to allocate to each other their aliquot shares of 72%-28%...
