Practice question
A corporation owes tax, while its shareholder separately owns a parcel in an individual capacity. Explain why the corporation's Section 219 lien does not automatically cover that parcel merely because of share ownership. Assume no independent ground of shareholder liability or disregard of personality.
Legal references
- NIRC Section219, Nature and Extent of Tax Lien; https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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