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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Letter of Authority vs. Letter Notice: When a BIR Tax Assessment Is Void
The Supreme Court ruled that a BIR Letter Notice cannot substitute for a Letter of Authority—assessments without a valid LOA are void.
Letter of Authority Required When Reassigning Tax Audits: Supreme Court Ruling
Supreme Court nullifies tax assessments where audits were reassigned without a new Letter of Authority. Learn the rules.
When a Revenue Officer Lacks Authority: The LOA Requirement in Tax Audits
Philippine Supreme Court explains why a new Letter of Authority is required when tax investigations are reassigned to another revenue officer.
When a Tax Audit Lacks Authority: The LOA Requirement in Philippine Tax Investigations
Philippine Supreme Court ruling on why BIR revenue officers need a valid Letter of Authority to conduct tax audits, and what happens when reassignments bypass this requirement.
Mastering Tax Assessments: The Timeliness and Validity of Protests in the Philippines
Learn how the Supreme Court protects taxpayers' due process rights when BIR reassigns revenue officers mid-audit without a new Letter of Authority.
Navigating Tax Assessments: The Validity of Letters of Authority in the Philippines
Learn when a BIR Letter of Authority becomes invalid, the 30-day and 120-day rules, and how the Supreme Court ruled in AFP General Insurance.
BIR Assessments Without a Letter of Authority Are Void for Lack of Due Process
Philippine Supreme Court voids BIR deficiency assessments issued without a Letter of Authority, and clarifies HMO gross receipts for VAT.
HMO VAT Assessments Void Without Letter of Authority: Medicard Case
Supreme Court voids HMO VAT assessment without Letter of Authority; only service fees, not earmarked medical funds, are taxable gross receipts.
Directors' Bonuses and Withholding Tax: Clarifying Employee Status in Philippine Tax Law
Philippine Supreme Court ruling on directors' bonuses, withholding tax on compensation, and the definition of received a Letter of Authority in 1998 to examine its books for taxable year 1997. Followi