Title II — TAX ON INCOME
(4) Premiums paid on any life insurance policy covering the life of any
officer or employee, or of any person financially interested in any
trade or business carried on by the taxpayer, individual or corporate,
when the taxpayer is directly or indirectly a beneficiary under such
policy.
(B)
Losses from Sales or Exchanges of Property. — In computing net
income, no deduction shall in any case be allowed in respect of losses from
sales or exchanges of property directly or indirectly —
(1) Between members of a family. For purposes of this paragraph, the
family of an individual shall include only his brothers and sisters
(whether by the whole or half-blood), spouse, ancestors, and lineal
descendants; or
(2) Except in the case of distributions in liquidation, between an
individual and a corporation more than fifty percent (50%) in value
of the outstanding stock of which is owned, directly or indirectly, by
or for such individual; or
(3) Except in the case of distributions in liquidation, between two
corporations more than fifty percent (50%) in value of the
outstanding stock of each of which is owned, directly or indirectly,
by or for the same individual, if either one of such corporations, with
respect to the taxable year of the corporation preceding the date of
the sale or exchange was, under the law applicable to such taxable
year, a personal holding company or a foreign personal holding
company;
(4) Between the grantor and a fiduciary of any trust; or
(5) Between the fiduciary of a trust and the fiduciary of another trust if
the same person is a grantor with respect to each trust; or
(6) Between a fiduciary of a trust and a beneficiary of such trust.
SEC. 37. Special Provisions Regarding Income and Deductions of Insurance
Companies, Whether Domestic or Foreign. —
(A)
62
Special Deductions Allowed to Insurance Companies. — In the case of
insurance companies, whether domestic or foreign doing business in the
Philippines, the net additions, if any, required by law to be made within
the year to reserve funds and the sums other than dividends paid within
the year on policy and annuity contracts may be deducted from their gross
income: Provided, however, That the released reserve be treated as income
for the year of release.
Isla Lipana & Co., the Philippine member firm of the PwC network
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