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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How to Protest a BIR Tax Assessment in the Philippines
Learn the step-by-step procedure to protest a BIR tax assessment in the Philippines, including deadlines, required documents, and remedies under the NIRC.
Tax Assessment Time Limits: How a Missed Deadline Can Save You Millions
Philippine Supreme Court ruling on tax assessment prescription periods, false returns, and why the BIR's missed deadlines can invalidate deficiency assessments.
Tax Assessment vs Tax Refund: Know Your Rights Under the Local Government Code
The Supreme Court clarifies when taxpayers may claim a refund under Section 196 instead of protesting an assessment under Section 195 of the Local Government Code.
When Tax Assessments Are Not Required: Civil Liability in Philippine Tax Evasion Cases
Philippine Supreme Court clarifies when a formal BIR tax assessment is not required to hold taxpayers civilly liable in criminal tax evasion cases.
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.
Due Process in Tax Assessments: When BIR Service of Notices Fails
Supreme Court voids BIR deficiency assessments served on unauthorized persons, stressing strict due process rules in tax collection.
Local Tax Assessments After Corporate Restructuring: Who Pays?
Supreme Court rules on who bears local business tax liability when a government corporation's operations transfer by law to another entity.
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.
Due Process in Tax Assessments: Strict Adherence to Notice Requirements
The Supreme Court nullified a deficiency tax assessment because the BIR issued the Final Assessment Notice before the taxpayer's 15-day period to reply to the Preliminary Assessment Notice lapsed.
Tax Assessment Validity: Waivers and Due Dates Under Scrutiny
The Supreme Court nullified BIR deficiency assessments for First Gas Power due to defective waivers and missing due dates, clarifying prescriptive period rules.
Prescription in Tax Assessments: Waivers Must Be Strictly Compliant for Validity
Waivers of the tax prescription period are strictly construed. Missing the BIR's date of acceptance voids them, and assessments without due dates fail.
Due Process in Local Tax Assessments: Lessons from the National Power Corporation Case
The Supreme Court clarifies that local governments must observe due process in tax assessments, as shown in the National Power Corporation case.
Navigating Tax Assessments: The Critical Role of Due Process and Timely Notices
A taxpayer's right to due process in tax assessments, explained through a Supreme Court ruling on prescribed notices and void assessments.
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.
Due Process in Tax Assessments: Insights from the Yumex Philippines Case
The Supreme Court nullified a deficiency tax assessment for lack of due process. Learn the procedural rules from this landmark case.
Understanding TAX Assessments THE Importance OF Clear Factual Basis IN Philippine TAX Law
The Supreme Court clarifies that tax assessments must rest on solid factual grounds, not mere assumptions, to be valid and enforceable.
Navigating Tax Assessments: Understanding the Limits of Declaratory Relief in Philippine Tax Law
The Supreme Court clarifies when declaratory relief cannot be used to challenge tax assessments, reinforcing the rule against enjoining tax collection.
Navigating Tax Assessments: The Importance of Timely Appeals in the Philippines
Learn why timing matters in Philippine tax disputes and how missing an appeal deadline can forfeit a taxpayer's right to challenge an assessment.
Local Tax Refund Requisites and Procedures for Contesting Assessments
Learn the requisites for local tax refunds and the proper procedure for contesting local tax assessments in the Philippines.
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.
Understanding Tax Assessment and Collection Prescription: The BPI Case
The Supreme Court's BPI ruling explains when the BIR loses the right to assess and collect deficiency taxes—key lessons for taxpayers.
Understanding the Difference Between Tax Assessments and Compliance Notices in the Philippines
The Supreme Court clarifies why not all BIR notices are tax assessments, and what this means for taxpayers facing compliance letters.
Tax Assessments and Due Process: When Can a Taxpayer Appeal to the CTA?
Taxpayers must exhaust administrative remedies before appealing to the CTA. Learn the rules on protesting assessments.
Tax Injunctions and Declaratory Relief: Limits on Court Authority
The Supreme Court clarifies that courts cannot enjoin tax collection and that declaratory relief is not a proper remedy to contest tax assessments.