Bir Ruling 332-12
Bir Ruling 332-12
Bir Ruling 332-12
Gentlemen :
This refers to your letter dated April 12, 2012 stating that:
4. Equitable PCI Bank has since merged with BDO Unibank, Inc.,
the herein transferor being the surviving party.
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5. The Trustor now wants the trust res, particularly the Property
to be transferred to her name. TIAEac
You now request for a confirmation of opinion that in as much as the Deed
of Conveyance referred to involves no real transfer of ownership by BDO
Unibank, Inc. of the trust res back to the same trustor of a revocable trust, no
internal revenue tax is due thereon.
Furthermore, in BIR Ruling No. 031-99 dated March 19, 1999, this Office
has already ruled that:
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The Deed of Conveyance executed to terminate the trust relationship
between the successor entity and Liana Elena M. Romulo and the consolidation of
the legal title and beneficial ownership over the subject property is a conveyance
without monetary consideration, and as such not subject to the documentary stamp
tax imposed under Sec. 196 of the same Tax Code, as amended. However, the
notarial acknowledgment to such deed is subject to the documentary stamp tax of
P15.00 under Sec. 188 of the 1997 Tax Code.
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