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• ↓ September 16, 2026 Tax Update
• ↓ COURT OF TAX APPEALS (CTA) DECISIONS
• ↓ Thank You for Making This Possible.
• ↓ Dear Clients, Colleagues and Friends:
• ↓ August 26, 2026 Tax Updates
• ↓ COURT OF TAX APPEALS (CTA) DECISIONS
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"REASSIGNMENT OF AUDIT TO ANOTHER EXAMINER PRIOR TO THE PAN-STAGE REQUIRES A NEW LETTER OF AUTHORITY (LOA); MEMORANDUM OF ASSESSMENT ISSUED BY A REVENUE DISTRICT OFFICER IS NOT SUFFICIENT. The Tax Code requires that the examination of a taxpayer’s books be conducted only by revenue officers specifically authorized under a valid LOA; an LOA is a special authority granted to particular revenue officers, not a general authority that may be used by any BIR officer. The Supreme Court held that the reassignment or substitution of revenue officers without a new or amended LOA violates the taxpayer’s right to due process and usurps the statutory authority of the CIR or his duly authorized representative. Any reassignment or transfer of a case to other revenue officers requires the issuance of a new LOA. Here, the examiners, who conducted the examination and recommended the issuance of the PAN, were not authorized under a valid LOA; their supposed authority rested only on Memorandum of Assignment issued by the Revenue District Officer, which could not substitute for an LOA. The subsequent LOA likewise did not cure the defect because it was issued long after the PAN. Thus, the PAN issued based on the unauthorized examination was void for lack of valid authority and violation of due process. [(Ammex I-Support Corporation v. Commissioner of Internal Revenue (CIR), CTA Case No. 11192, April 17, 2026)]"

"PHRASES IN THE ASSESSMENT NOTICE “YOU ARE REQUESTED TO PAY” OR “IF YOU ARE AMENABLE” DO NOT NEGATE DEMAND TO PAY; ASSESSMENT REMAINS VALID. A valid assessment must constitute a written notice and demand for a definite tax liability and must indicate a clear due date for payment, because the demand signals when penalties and interest accrue and informs the taxpayer of its remedies. Applying these principles, the CTA held that the FLD and FAN contained an unequivocal demand despite using the phrase “you are requested to pay,” since a demand may properly take the form of a request for payment; here, the FAN stated a definite amount and expressly provided June 30, 2022 as the payment deadline. Moreover, the title “Formal Letter of Demand” itself indicated the CIR’s intention to demand payment, and the phrases “you are requested to pay” and “if you are amenable” did not negate the demand. Thus, the assessment notices validly demanded payment of the deficiency taxes. (Marina Square Properties, Inc. v. CIR, CTA Case No. 11092, June 29, 2026)"

"3-YEAR PRESCRIPTIVE PERIOD WAS EXTENDED BY 420 DAYS DUE TO COVID-19  PANDEMIC. Internal revenue taxes must generally be assessed within 3 years from the last day prescribed for filing the return or the actual filing date, whichever is later, subject to the suspension provisions; during the COVID-19 pandemic, various legislations/regulations validly suspended the running of the prescriptive period during the specified ECQ/MECQ period. Applying these rules, although the original 3-year periods for 2018 income tax, VAT, WTC, and EWT liabilities had generally expired before the FLD was issued, the CTA held that the applicable COVID-19 suspensions validly extended the prescriptive periods by 420 days; consequently, the BIR’s right to assess remained timely for all the deficiency taxes involved, before the FLD was issued and received (Marina Square Properties, Inc. v. CIR, CTA Case No. 11092, June 29, 2026)"

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September 16, 2026 Tax Update

COURT OF TAX APPEALS (CTA) DECISIONS

Thank You for Making This Possible.

Dear Clients, Colleagues and Friends:

August 26, 2026 Tax Updates

COURT OF TAX APPEALS (CTA) DECISIONS