Legal Insights
Plain-language guides and case briefs on Philippine law — researched from the firm's law library of 184,000+ statutes, Supreme Court decisions, and agency issuances, and written so non-lawyers can understand and act on them.
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Finality of Tax Assessments: Why Collection Efforts Don't Reopen Tax Disputes
When do collection letters and lawsuits reopen settled tax assessments? The Supreme Court clarifies in Pilipinas Shell v. Commissioner of Customs.
Retroactivity of Supreme Court Decisions on Tax Exemptions: CJH Development v. BIR
The Supreme Court clarifies when tax exemption rulings apply retroactively and why declaratory relief is not the proper remedy for contesting tax assessments.
Tax Assessment Validity: Balancing Revenue Collection and Taxpayer Rights in Evidence Disputes
The Supreme Court clarifies that illegally obtained documents do not automatically invalidate tax assessments, balancing BIR collection powers with taxpayer protections.
TAX Assessment Validity Strict Compliance AND Waiver Requirements
Tax Assessments and the Imperative of Timely Protests in Philippine Law
Learn how the Supreme Court ruled on tax assessment finality and why timely protests are crucial for taxpayers in the Philippines.
TAX Assessment Deadlines When Failure TO Prove Notice Means NO TAX DUE
Untangling Tax Assessment Appeals: Deadlines and Excusable Neglect
A bank missed the 30-day window to appeal its tax assessment to the CTA. The Supreme Court explains why deadlines are jurisdictional and when relief is unavailable.
Delegation of Authority in Tax Assessments: When a Subordinate's Demand Letter Becomes Final
Learn when a demand letter from a BIR subordinate officer counts as the Commissioner's final decision on a protested tax assessment, and why timing matters.
Tax Assessment and Collection: Understanding the 10-Year Rule in the Philippines
Learn when the 10-year prescriptive period applies to tax assessment and collection in the Philippines, explained through the Commissioner of Internal Revenue v. Tulio case.
Fair Market Value vs. Actual Use: Defining Real Property Tax Assessments in the Philippines
The Supreme Court strikes down a Quezon City ordinance that based real property tax on deed prices, reaffirming actual use and fair market value as the legal standards.
Tax Assessments and Double Jeopardy: Guarding Against Erroneous Government Actions
The Supreme Court clarifies the limits of double jeopardy protection in tax assessments, ensuring fair treatment for taxpayers facing repeated government actions.
Tax Assessment Validity: Strict Requirements for Waivers of the Statute of Limitations
Philippine Journalists, Inc. v. CIR clarifies that waivers of the tax prescription period must strictly comply with BIR regulations to be valid.
When Tax Assessments Become Final: Lessons from MERALCO's Garnishment Case
MERALCO's failed challenge to Muntinlupa's deficiency real property tax assessments shows why taxpayers must act promptly on tax notices.
TAX Assessment Validity Improperly Addressed Notices AND Corporate TAX Liabilities
Tax Assessment vs Collection Notices: Due Process in Real Property Tax Disputes
Supreme Court clarifies the vital distinction between tax assessment and collection notices, and what this means for taxpayers' remedies.
Finality of Tax Assessments: Timeliness, Gross Receipts, and the Security Guard Case
A look at Protector's Services v. CIR on tax assessment finality, prescriptive periods, and what counts as gross receipts.
Contractor's Tax Assessments: Prescription Periods and Gross Receipts Rules
Philippine Supreme Court ruling on tax assessment prescription periods, contractor's tax on security agency gross receipts, and protest deadlines under the NIRC.
Invalid Tax Assessment: Why an Affidavit for Criminal Complaint Does Not Count
The Supreme Court clarifies that a revenue officer's affidavit attached to a criminal complaint for tax evasion is not a formal assessment that can be appealed to the Court of Tax Appeals.
Invalid Tax Assessments: Why Evidence Matters in Philippine Tax Law
When can tax assessments be invalidated? The Supreme Court explains why evidence matters in Philippine tax law.
Tax Assessment Waivers: Why the BIR Commissioner's Signature Is Crucial
Philippine Supreme Court ruling on why waivers of the tax prescription period require the BIR Commissioner's signature to be valid.
Tax Assessment Deadlines: How the Supreme Court Protects Taxpayers From Belated BIR Claims
The Supreme Court ruled the BIR cannot issue deficiency assessments beyond the five-year prescriptive period, protecting taxpayers from belated claims.
When Real Property Tax Assessments Can Be Challenged: Lessons from Callanta v. Ombudsman
Philippine Supreme Court ruling on when property owners may challenge real property tax assessments and the limits of city assessors' authority.
Estate Tax Collection: BIR Authority vs. Probate Court Jurisdiction
Supreme Court ruling on whether the BIR can levy estate properties without probate court approval, and the finality of tax assessments.
Tax Evasion vs Deficiency: When Can the Government Prosecute?
Philippine Supreme Court explains when the government can file tax evasion charges and when a final tax assessment must come first.