Professional Documents
Culture Documents
○ Ordinary
○ Necessary
○ Paid or incurred during the taxable year
○ Directly attributable to the development, management, operation, and/or conduct of the
business (Sec. 34, NIRC)
Business expenses
Commissioner of Internal Revenue vs. Isabela Cultural Corporation (February 12, 2007)
Accrual Method applied to legal and audit expenses
ING Bank, N.V. vs. Commissioner of Internal Revenue (July 22, 2015)
Accrual of Bonus granted to employees – when to accrue
Commissioner of Internal Revenue vs. General Foods (Phils.) Inc. (April 24, 2003)
Advertising Expense of General Foods
Commissioner of Internal Revenue vs. Lancaster Philippines, Inc. (July 12, 2017)
Crop Method of Accounting
C.M. Hoskins & Co., Inc. vs. Commissioner of Internal Revenue (November 28, 1969)
Kuenzle & Streiff, Inc. vs. Collector of Internal Revenue (October 20, 1959)
Paper Industries Corporation of the Philippines vs. Court of Appeals (December 1, 1995)
Commissioner of Internal Revenue vs. Vda. de Prieto (September 30, 1960) RR 13-2000
(November 20, 2000)
Interest arbitrage
Taxes
Losses
Forex Losses
BIR Ruling 206-90 (30 October 1990)
BIR Ruling No. 144-85 (26 August 1985)
Bad Debts
Philex Mining Corporation vs. Commissioner of Internal Revenue (16 April 2008)
Philippine Refining Company vs. Court of Appeals (8 May 1996)
Fernandez Hermanos, Inc. vs. Commissioner of Internal Revenue (30 September 1969)
Depreciation
RR 12-2012
Depletion
Section 34(L), Tax Code as amended by Republic Act Nos. 9504 and 10963
Esso Standard Eastern, Inc. vs. Commissioner of Internal Revenue (7 July 1989(
Section 119-122, RR 2