Practice question
A corporation organized under foreign law maintains a Philippine branch and has stipulated Philippine-source business income and unrelated stipulated foreign-source income. Under Section 23(F), absent a special rule, which source coverage applies?
- Worldwide coverage because it has a Philippine branch
- Philippine-source coverage; a local branch does not itself make the corporation domestic
- No Philippine coverage because it is foreign
- Only income paid in foreign currency
- Worldwide coverage solely because the branch employs Filipinos
Legal references
- NIRC Sections 4,22,23 and244: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/2/3896
- RA12066, CREATE MORE Act: https://lawphil.net/statutes/repacts/ra2024/ra_12066_2024.html
- RA12214, Capital Markets Efficiency Promotion Act: https://lawphil.net/statutes/repacts/ra2025/ra_12214_2025.html
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