CIR v.

Campos Rueda
Respondent Campos Rueda is administrator of the estate of deceased Maria Cedeira, a Spanish national
by reason of marriage to a Spanish citizen, and resident of Tangier, Morocco until her death. CIR
assessed him of estate and deficiency taxes on the transfer of intangible personal properties situated in
the Philippines and belonging to Maria Cedeira. Campos Rueda claimed a certain amount covering
intangible personal properties exempt from taxes, which was denied by CIR on the ground that the law
of Tangier, Morocco is not reciprocal with Sec. 122 of the NIRC, which was moreover a mere principality
and not a foreing country.

WON the IPPs of Maria Cederia are exempt from estate and inheritance taxes? – Yes, as provided in Sec.
122 of the NIRC. Even a tiny principality, hardly an international personality in the sense, still falls under
the exempt category.

“Foreign country” under section 122 of NIRC refers to a government of that foreign power which
although not an international person in the sense of international law does not impose transfer or death
upon intangible person properties of our citizens not residing therein whose law allow a similar
exemption from such taxes.