Practice question
A Philippine citizen lived abroad at death and owned assets in several countries. Explain why the Code's nonresident-alien territorial restriction cannot be applied solely from overseas residence.
Legal references
- NIRC Sections84-85,98 and104, read with TRAIN amendments: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- RA10963, TRAIN, estate and donor tax amendments including Sections99-100: https://lawphil.net/statutes/repacts/ra2017/ra_10963_2017.html
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