Title II — TAX ON INCOME
such credits in the year in which the taxes of the foreign country
accrued, the credits for all subsequent years shall be taken upon the
same basis, and no portion of any such taxes shall be allowed as a
deduction in the same or any succeeding year.
(7) Proof of Credits. — The credits provided in Subsection (C)(3) hereof
shall be allowed only if the taxpayer establishes to the satisfaction of
the Commissioner the following:
(a) The total amount of income derived from sources without the
Philippines;
(b) The amount of income derived from each country, the tax paid
or incurred to which is claimed as a credit under said paragraph,
such amount to be determined under rules and regulations
prescribed by the Secretary of Finance; and
(c) All other information necessary for the verification and
computation of such credits.
(D)
Losses. —
(1) In General. — Losses actually sustained during the taxable year and
not compensated for by insurance or other forms of indemnity shall
be allowed as deductions:
(a) If incurred in trade, profession or business;
(b) Of property connected with the trade, business or profession, if
the loss arises from fires, storms, shipwreck, or other casualties,
or from robbery, theft or embezzlement.
The Secretary of Finance, upon recommendation of the
Commissioner, is hereby authorized to promulgate rules and
regulations prescribing, among other things, the time and
manner by which the taxpayer shall submit a declaration of loss
sustained from casualty or from robbery, theft or embezzlement
during the taxable year: Provided, however, That the time
limit to be so prescribed in the rules and regulations shall not
be less than thirty (30) days nor more than ninety (90) days
from the date of discovery of the casualty or robbery, theft or
embezzlement giving rise to the loss.
(c) No loss shall be allowed as a deduction under this Subsection if
at the time of the filing of the return, such loss has been claimed
as a deduction for estate tax purposes in the estate tax return.
(2) Proof of Loss. — In the case of a nonresident alien individual or
foreign corporation, the losses deductible shall be those actually
National Internal Revenue Code of 1997 (as amended by the TRAIN Law, RAs 11256, 11346 and 11467)
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