Taxation Law Philippine Bar Question and Answer 2009 to 2019

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Front T/FProceedings before the CTA in the exercise of its exclusive original jurisdiction are in the nature of trial de novo. (1%)
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Front Which statement is WRONG? (2012 BAR) a) The power of taxation may be exercised by the government, its political subdivisions, and public utilities; b) Generally, there is no limit on the amount of tax that may be imposed; c) The money contributed as tax becomes part of the public funds; d) The power of tax is subject to certain constitutional limitations.
Back SUGGESTED ANSWER: a) The power of taxation may be exercised by the government, its political subdivisions, and public utilities
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Front You are the retained tax counsel of ABC Corp. Your client informed you that they have been directly approached with a proposal by a BIR insider (i.e., a middle rank BIR official) on the tax matter they have referred to you for handling. The BIR insider's proposal is to settle the matter by significantly reducing the assessment, but he will get 50% of the savings arising from the reduced assessment. What tax, criminal and ethical considerations will you take into account in giving your advice? Explain the relevance of each of these considerations. (2013 Bar Question)
Back SUGGESTED ANSWER: As a lawyer, I have the responsibility to give only a lawful advice. Canon I of the Code of Professional Responsibility mandates me to “uphold the Constitution, obey the laws of the land and promote respect for law and legal processes. Rule 1.01 states that “a lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct.” Rule 1.02 provides that “a lawyer shall not counsel or abet activities aimed at defiance of the law or at lessening confidence in the legal system.” Therefore, I will advise my client not to agree with the proposal of the BIR officer. Agreeing with the proposal will result in criminal prosecution under the following laws: Under the NIRC, the officers of the board who authorized the tax evasion will be liable under Section 253(C), while the corporation shall be liable under Section 256. The BIR official is liable under Section 269 which provides for the violations committed by government enforcement officers. Paragraph (d) of Section 269 provides that one of these violations is “offering or undertaking to accomplish, file or submit a report or assessment on a taxpayer without the appropriate examination of the books of accounts or tax liability, or offering or undertaking to submit a report or assessment less than the amount due the Government for any consideration or compensation, or conspiring or colluding with another or others to defraud the revenues or otherwise violate the provisions of this Code.” Under the Revised Penal Code, the officers of the corporation shall be liable under Article 212 for corruption of public officials while the BIR official is liable for direct bribery. Both my client and the BIR official will also be liable under Republic Act No. 3019 or the Anti- Graft and Corrupt Practices Act.
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