Title II — TAX ON INCOME Philippines with respect to his income derived from sources abroad until the date of his arrival in the Philippines. (5) The taxpayer shall submit proof to the Commissioner to show his intention of leaving the Philippines to reside permanently abroad or to return to and reside in the Philippines as the case may be for purposes of this Section. (F) The term ‘resident alien’ means an individual whose residence is within the Philippines and who is not a citizen thereof. (G) The term ‘nonresident alien’ means an individual whose residence is not within the Philippines and who is not a citizen thereof. (H) The term ‘resident foreign corporation’ applies to a foreign corporation engaged in trade or business within the Philippines. (I) The term ‘nonresident foreign corporation’ applies to a foreign corporation not engaged in trade or business within the Philippines. (J) The term ‘fiduciary’ means a guardian, trustee, executor, administrator, receiver, conservator or any person acting in any fiduciary capacity for any person. (K) The term ‘withholding agent’ means any person required to deduct and withhold any tax under the provisions of Section 57. (L) The term ‘shares of stock’ shall include shares of stock of a corporation, warrants and/or options to purchase shares of stock, as well as units of participation in a partnership (except general professional partnerships), joint stock companies, joint accounts, joint ventures taxable as corporations, associations, and recreation or amusement clubs (such as golf, polo or similar clubs), and mutual fund certificates. (M) The term ‘shareholder’ shall include holders of a share/s of stock, warrant/s and/or option/s to purchase shares of stock of a corporation, as well as a holder of a unit of participation in a partnership (except general professional partnerships) in a joint stock company, a joint account, a taxable joint venture, a member of an association, recreation or amusement club (such as golf, polo, or similar clubs) and a holder of a mutual fund certificate, a member in an association, joint-stock company, or insurance company. 14 (N) The term ‘taxpayer’ means any person subject to tax imposed by this Title. (O) The terms ‘including’ and ‘includes’, when used in a definition contained in this Title, shall not be deemed to exclude other things otherwise within the meaning of the term defined. Isla Lipana & Co., the Philippine member firm of the PwC network

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