June 10, 2002
REVENUE MEMORANDUM RULING NO. 02-02
| SUBJECT | : | Determination of Substituted Basis of Property Transferred and Shares Received, Pursuant to Section 40(C)(5) of the National Internal Revenue Code of 1997 |
| TO | : | All Internal Revenue Officers and Others Concerned |
I. Scope
Pursuant to Section 4 in relation to Section 40(C)(5) and other pertinent provisions of Title II of the National Internal Revenue Code of 1997 (Tax Code of 1997), this Revenue Memorandum Ruling is issued to provide the guidelines provided by Section 40(C)(5) of the Tax Code of 1997 in determining the substituted basis of property transferred and shares received, pursuant to a tax-free exchange of property for shares of stock under Section 40(C)(2) of the Tax Code of 1997, which shall be annotated on the transfer certificate of title, condominium certificate of title, or certificate of stock of such property/shares, pursuant to the provisions of Revenue Regulations No. 18-2001 dated November 18, 2001. This Revenue Memorandum Ruling shall apply solely and exclusively to, and may be relied upon only in situations in which the facts are substantially...
