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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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.
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.
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 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.
Due Process in Tax Assessments: When the BIR's Failure to Consider a Taxpayer's Protest Invalidates Assessment
The Supreme Court clarifies that the BIR's failure to consider a taxpayer's protest and evidence violates due process, rendering tax assessments null and void.
Due Process in Tax Assessments: BIR Must Consider Taxpayer Evidence
When BIR ignores taxpayer evidence in tax assessments, due process is violated and assessments are void. Learn from Avon case.
Real Property Tax Disputes: Why Payment Under Protest Is a Mandatory First Step
Philippine Supreme Court clarifies that payment under protest is mandatory before appealing real property tax assessments, even when claiming tax exemption.
Tax Assessments Invalid Notices and Taxpayer Due Process in the Philippines
Philippine Supreme Court ruling on invalid tax assessment notices and taxpayer due process rights explained in plain language.
Tax Refunds and Court Discretion: When Can a Taxpayer Withdraw an Appeal
The Supreme Court clarifies when a Final Decision on Disputed Assessment is void and its effect on tax assessments.
When Waivers Fail: Prescription and Due Process in Tax Assessments
A waiver of the tax prescription period must strictly follow BIR rules; defects void it and bar assessment.