Practice question
A shareholder owns personal land wholly separate from a corporation. Only the corporation owes the assessed internal-revenue tax. The BIR relies solely on Section 219 and share ownership to claim the shareholder's land, with no piercing, transferee liability, agency, or other basis. What follows?
- Section 219's taxpayer-property requirement is not satisfied merely by the shareholder relationship.
- All shareholder property automatically belongs to every corporation.
- Every corporate tax lien transfers title to all relatives' land.
- Separate ownership is irrelevant in every tax case.
- The shareholder must donate the land to establish ownership.
Legal references
- NIRC Section219, Nature and Extent of Tax Lien; https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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