1.

Tax amnesty is immunity from all criminal, civil and administrative liabilities
arising from non-payment of taxes. It is a general pardon given to all
taxpayers. It applies only to past tax periods, hence of retroactive application.
(People vs. Castaneda, GR No. L-46881)

Tax exemption is an immunity from the civil liability only. It is an immunity or

privilege, a freedom from a charge or burden to which others are subjected.
It is generally prospective in application.

2. No. The President of the Philippines is not empowered to grant tax exemption
as this power is lodged solely with Congress. Taxation being legislative in
character can be exercised only by the lawmaking body. This rule is also true
to the granting of exemption. What one cannot impose, one can not
condone

3. No. The act of exemption is an act of taxation which is inherently legislative

and, therefore, a mere executive agreement without concurrence by
Congress cannot provide for a tax exemption.

Alternative: It is valid. The stipulation in the agreement that the lender shall
be made free and clear from all Philippine taxes simply meant that the
Central Bank will assume the tax liability which is not contrary to law, morals,
good customs, public order or public policy.

4. The income tax liability of X can not be compensated with the amount owed
by the Government as compensation for his property expropriated, taxes are
of distinct kind, essence and nature than ordinary obligations. Taxes and
debts cannot be the subject of compensation because the Government and X
are not mutually creditors and debtors of each other and a claim for taxes is
not a debt, demand, contract, or Judgment as is allowable to be set off.
(Francia vs. IAC. G.R 76749, June 28. 1988)

5. Tax exemptions are strictly construed against the taxpayer because such
provisions are highly disfavored and may almost be said to be odious to the
law (Manila Electric Company vs. Vera, 67 SCRA 351). The exception
contained in the tax statutes must be strictly construed against the one
claiming the exemption because the law does not look with favor on tax
exemptions they being contrary to the life-blood theory which is the
underlying basis for taxes.