Tax exemption; basis, extent, object

BASIS: Tax exemption may be constitutional, statutory, contractual or treaty. In other words, it may be granted by the Constitution, by law created by Congress or by valid treaty stipulations.

EXTENT: Tax exemption may also be total or partial. It is total when the taxpayer is absolutely not required to pay a particular tax. It is partial when only a part of the tax is waived by the State.

OBJECT: Tax exemption may be direct or indirect. It is direct (personal) if it favors certain persons. If it favors a class of property, it is indirect. In other words, it is direct if a person is exempt from paying the tax; if property or business is exempt, it is indirect (because the ultimate beneficiary is the person who owns the property or business).