Professional Documents
Culture Documents
B. Nature of taxation
C. Characteristics of taxation
E. Purpose of taxation
1. Revenue-raising
2. Non-revenue/special or regulatory
Phil. Guaranty Co., Inc. v. CIR, GR No. L-22074, April 30, 1965
Commissioner v. Algue, supra
H. Doctrines in taxation
1. Prospectivity of tax laws
2. Imprescriptibility
3. Double taxation
a. Strict sense
b. Broad sense
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Villanueva v. City of Iloilo, 26 SCRA 528 (1968)
b. Tax avoidance
c. Tax evasion
7. Compromise
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8. Tax amnesty
a. Definition
b. Distinguished from tax exemption
a. Tax laws
i. General rule
ii. Exception
i. General rule
ii. Exceptions
a. Public Purpose
b. Inherently legislative
i. General rule
ii. Exceptions
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1. Delegation to local governments
c. Territorial
i. Situs of taxation
1. Meaning
2. Situs of income tax
a. From sources within the Philippines
d. International comity
2. Constitutional limitations
i. Due process
J. Stages of taxation
1. Levy
2. Assessment and collection
3. Payment
4. Refund
K. Definition, nature and characteristics of taxes
L. Requisites of a valid tax
M. Tax as distinguished from other forms of exactions
1. Tariff
2. Toll
3. License fee
4. Special Assessment
5. Debt
N. Kinds of taxes
1. As to object
a. Personal, capitation, or poll tax
b. Property tax
c. Privilege tax
2. As to burden or incidence
a. Direct
b. Indirect
3. As to tax rates
a. Specific
b. Ad valorem
c. Mixed
4. As to purposes
a. General or fiscal
b. Special, regulatory or sumptuary
5. As to scope or authority to impose
a. National – internal revenue taxes
b. Local – real property tax, municipal tax
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6. As to graduation
a. Progressive
b. Regressive
c. Proportionate
A. Nature of Laws
B. Sources of Tax Laws
a. Constitution
b. National Internal Revenue Code
c. Tariff and Customs Code
d. Local Government Code
e. Local tax ordinance
f. Tax treaties/international agreements
g. Special laws
h. Decisions of the SC/CTA
i. Revenue rules and regulations/ Administrative rulings and opinions
2. BIR Rulings
i. General
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ii. Application of revenue rules and regulations/rulings
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