BIR Ruling No. 570-2017

REPUBLICOF THE PHUHPPINES

BUREAU OF INTERNAL REVENUE DIPARIANTOFHNANGF Quezon City

SECS. 90 (C), 91 (B) & 249 i NIRC of 1997. as amended: BIR Ruling No. 276-2015 Revenue Regutations (RR) No. 02-2003 570-2017 2-7-07

Puerto Princesa City. Palawan SYLVIE MESSINA Princesa Homes. Wescom Rd..

Madam:

estate tax due pursuant to Sections 90 (C) and 91 (B). respectively, of the National of Jean Marc Messina for an extension of time to file the estate tax return and pay the Internal Revenue Code of 1997, as amended. This refers to your letter dated July l2, 2016 requesting on behalf of the heirs

amount of estate tax due: and that due to the foregoing, you are requesting for an with the probation of the will; that you are also gathering all the relevant documents. documents necessary to properiy accomplish the estate tax return and determine the extension of thirty (30) days to file the estate tax return and five (5) years to fully pay the estate tax duc thercon. engaging the services of appraisers and other professional to assist in determining the correct asset valuations for estate tax purposes: that the heirs of Jean Marc Messina are all residents of France and it is very difficult for you to obtain all the information and you are in the process of preparing and coliating the documents required in connection It is represented that Jean Marc Messina died testate on January 27. 2016: that

National Internal Revenue Code of 1997, as amended, provide. viz.: In reply thereto, please be informed that Sections 90 (C) and 91 (B) of the

"SEC. 90. Estate Tax Returns. -

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to grant, in meritorious cases. a reasonable extension not exceeding thirty (30) days for filing the return. " (() Extension of Time. - The Comnissioner shall have authority

"SEC.. 91. Pavment of tax.

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extend the time for pavment of such tax or any part thereof not to exceed vears in case the estate is settled extrajudicially. In such case, the unount in respect of which the extension is granted shall he paid on or inipose undue hardship upon the estate or any of the heirs, he may five (5) years, in case the estate is settled through the courts. or two (2) rimning of the Statute of Limitations for assessment as provided in payment on the due date of the estate tax or of amy part thereof would before the date of the expiration of the period of the extension, and the (B) Extension of Tine. - When the Commissioner finds thut the

ESTATE TAX (F JEAN MARC MESSINA r570-2017 1?-7-207

Section 203 of this (Code shall be suspended for the period of any such extension.

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the payment of the said tax in accordance with the terms of the or administrator. or beneficiary, as the case may he" to furnish a hond in such umount, not exceeding douhle the amount of the tax and with such sureties as the Commissioner deems necessary, conditioned upon If an extension is granted. the Commissioner may require the executor. extension.

hereby extended up to August 24, 2016. from July 25. 2016. which is the last day for filing of the estate tax return of the late Jean Marc Messina. Thus. the filing of the said estate tax return of the decedent is grant the request for an extension to file the estate tax return of thirty (30) days counted Based on the foregoing representations. this Officc finds justifiable reason to

tax is hercby granted up to the maximum period of five (5) years; reckoned from actual filing of the return or on August 24, 2016, whichever comes first, provided that the executor. or administralor. or beneficiary, shall furnish a bond in such amount, nol cxceeding double thc amount of the tax and with such sureties as the Commissioner deems necessary, conditioned upon the payment of the said tax in accordance with the terms of the extension. Moreover, your request for extension of the time within which to pay the estate

corresponding interest that shall have accrued thereon up to the time of payment of the pursuant lo Section 249 of the National Internal Revenue Code of 1997. as amended. estate tax due on the transmission by the said estate of its properties in favor of the hcirs It shalt be understood. however, that the estate shail be liable for the

However. if upon investigation, it will be disclosed that the facts are different. then this ruling shail be considered null and void. This ruling is being issued on the basis of the foregoing facts as represented

Very truly yours.

18301

Commissioner of Internal Reverwe CAESAR R. DULAY 0f1'67

TK-I-LMAT

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