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October 23, 2018ITAD BIR RULING NO. 114-18Article 21 (Teachers) Philippines-United States of America tax treatyInternational School ManilaUniversity ParkwayFort Bonifacio1634 Taguig CityAttention: AAA_______________Gentlemen :This refers to your tax treaty relief applications filed on December 10, 2012 requesting confirmation that remuneration paid by International School Manila, Inc. ("International School") to BBB and CCC is exempt from income tax pursuant to the Convention between the Government of the Republic of the Philippines and the Government of the United States of America with Respect to Taxes on Income ("Philippines-United States tax treaty").FACTSIt is represented that BBB and CCC are American citizens and residents of the United States based on their passports and Certificates of Residence issued by the Internal Revenue Service; that their names are not registered business names in the Philippines based on a certification issued by the Department of Trade and Industry; that they have Overseas Hire Contracts with International School where they were contracted to teach for school years August 2011 to July 2013; and that International School is a private, non-profit, non-sectarian day school for...