No date supplied
BIR RULING NO. 103-61
Messrs. Sycip, Gorres, Velayo & Co.
Certified Public Accountants
490 San Luis, Manila
Gentlemen :
This is in connection with your letter dated February 11, 1961, requesting a ruling on the question of whether or not capital gains realized by non-resident aliens not engaged in trade or business in the Philippines from the sale or disposition of capital assets held for more than twelve months, shall be taxed only to the extent of 50% of such gains. LLphil
The pertinent provision of Section 23(b) of the Tax Code as amended by Republic Act No. 2343 reads as follows:
"Sec. 22(b) Nonresident alien not engaged in trade or business within the Philippines. — There shall be levied, collected and paid for each taxable year upon the entire income received from all sources within the Philippines by every nonresident alien individual not engaged in trade or business within the Philippines as interest, dividends, rents, salaries, wages, premiums, annuities, compensations, remuneration, emoluments, or other fixed or determinable annual or periodical gains, capital gains, profits, and income, a tax equal...
