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CIR v. CA

This case has been cited 5 times or more.

	GR No. 198756 2015-01-13	BANCO DE ORO v. REPUBLIC LEONEN, J.
"The application of the withholdings system to interest on bank deposits or yield from deposit substitutes is essentially to maximize and expedite the collection of income taxes by requiring its payment at the source."[202]
	GR No. 176959 2010-09-08	METROPOLITAN BANK v. BOARD OF TRUSTEES: RIVERSIDE MILLS CORPORATION PROVIDENT CASE VILLARAMA, JR., J.
Employees' trusts or benefit plans are intended to provide economic assistance to employees upon the occurrence of certain contingencies, particularly, old age retirement, death, sickness, or disability. They give security against certain hazards to which members of the Plan may be exposed. They are independent and additional sources of protection for the working group and established for their exclusive benefit and for no other purpose.[18] Here, while the Plan provides for a reversion of the Fund to RMC, this cannot be done until all the liabilities of the Plan have been paid. And when RMC ceased operations in 1984, the Fund became liable for the payment not only of the benefits of qualified retirees at the time of RMC's closure but also of those who were separated from work as a consequence of the closure. Paragraph 7 of the Retirement Plan states: Separation from Service:
	GR No. 162175 2010-06-28	MIGUEL J. OSSORIO PENSION FOUNDATION v. CA CARPIO, J.
Petitioner is a corporation that was formed to administer the Employees' Trust Fund. Petitioner invested P5,504,748.25 of the funds of the Employees' Trust Fund to purchase the MBP lot. When the MBP lot was sold, the gross income of the Employees' Trust Fund from the sale of the MBP lot was P40,500,000. The 7.5% withholding tax of P3,037,500 and broker's commission were deducted from the proceeds. In Commissioner of Internal Revenue v. Court of Appeals,[44] the Court explained the rationale for the tax-exemption privilege of income derived from employees' trusts: It is evident that tax-exemption is likewise to be enjoyed by the income of the pension trust. Otherwise, taxation of those earnings would result in a diminution of accumulated income and reduce whatever the trust beneficiaries would receive out of the trust fund. This would run afoul of the very intendment of the law.
	GR NO. 138919 2006-05-02	FAR EAST BANK v. CIR TINGA, J.
On four dates, 12 May 1993, 16 August 1993, 31 January 1994, and 29 April 1994, petitioner filed its written claim for refund with the Bureau of Internal Revenue (BIR) for the first, second, third and fourth quarters of 1993, respectively. Petitioner cited this Court's "precedent setting" decision in Commissioner of Internal Revenue v. Court of Appeals,[5] promulgated on 23 March 1992, said case holding that employees' trusts are exempted by specific mandate of law from income taxation. Nonetheless, the claims for refund were denied.
	GR No. 144516 2004-02-11	DEVELOPMENT BANK OF PHILIPPINES v. COA CARPIO, J.
In the present case, the DBP Board of Governors' (now Board of Directors) Resolution No. 794 and the Agreement executed by former DBP Chairman Rafael Sison and the trustees of the Plan created an express trust, specifically, an employees' trust. An employees' trust is a trust maintained by an employer to provide retirement, pension or other benefits to its employees.[29] It is a separate taxable entity[30] established for the exclusive benefit of the employees.[31]