May 28, 2010
BIR RULING [DA-(JV-017) 077-10]
Secs. 22 (B); 27 (A); 196; RR 2-98;
BIR Ruling Nos. 153-99; 075-97; DA-373-08;
DA-356-08; DA-319-08; DA-196-08; DA-455-07
SGV & Co.
6760 Ayala Avenue
Makati City
Attention: Atty. M. F. A. Balili
Partner
Gentlemen :
This refers to your letter dated April 2, 2009 requesting on behalf of your client, Federal Land Inc. ("FLI"), for a confirmation on the tax consequences of its joint venture agreement with Metropolitan Bank & Trust Company ("MBTC") for the development of two (2) condominium projects known as the "The Oriental Place" and The Capital Towers (collectively known as the "Projects").
The facts as represented are as follows:
FLI is a real estate developer for residential, commercial and mixed-use property developments in Metro Manila. MBTC, on the other hand, is the absolute and registered owner of four (4) parcels of land located at Chino Roces Avenue and Javier Street, Brgy. Kayamanan "A", Makati City, with an aggregate area of One Thousand Six Hundred Sixty Seven (1,667) square meters, more or less, covered by Transfer Certificates of Title (TCT) Nos. 200910, 200911, 200912 and 200913...
