Member Article

SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for October.

The October 2023 issue covers the following tax issues:

1. In cases of real property taxes ("RPT") on land covered by the Torrens system, can treasurers of local governments rely on the certificates of title to determine the owner of the land for purposes of sending notices of deficiency RPT?

2. Is the 60-day period to submit supporting documents for a request for reinvestigation under a protest to a Final Assessment Notice/Final Letter of Demand ("FAN/FLD") for deficiency taxes counted from the date of the filing of said protest?

3. May the Court of Tax Appeals declare, as void and inoperative, the provision of a local government unit's revenue code - which requires the prior payment of local business taxes before entertaining a protest - even if the taxpayer did not follow the procedure for nullifying the provision in accordance with Section 187 of the Local Government Code?

4. When is prior notice and hearing required for a revenue issuance to be valid?

5. What taxes are due on transactions involving real properties considered as ordinary assets?

6. What are the modes of service for warrants of garnishment against the bank deposits of a delinquent taxpayer?

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