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Are the peace bonds deposits substitutes or not?

From your answer explain the tax consequence,


use the image below as your guide.
Peace Bonds are NOT Substitutes the case decided by the Supreme Court by involving eight
banks and its principal the issue of the taxability of interest income in a zero coupon bonds
known as PEACe Bonds deposit substitutes subject to taxations. The Supreme Court did not
consider the PEACe Bonds as deposit substitutes and not subject to the 20 percent final
withholding tax on the interest on deposit substitutes due to the failure to adequately show that
there was borrowing from the public. There was, however, a qualification that should there have
been a simultaneous sale of the bonds from BTr and RCBC/CODE-NGO and from
RCBC/CODE-NGO to the undisclosed investors, and the total number of the investor/lender
exceeded twenty (20), the PEACe Bonds would have been considered as deposit substitutes.

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