CASE DIGEST: CIR v. Anglo California National Bank (G.R. No. L-12476)

CASE DIGEST: G.R. No. L-12476, Jan. 29, 1960. COLLECTOR OF INTERNAL REVENUE, petitioner, vs. ANGLO CALIFORNIA NATIONAL BANK (CROCKER-ANGLO NATIONAL BANK), as Treasurer for CALAMBA SUGAR ESTATE, INC., respondent.

FACTS: The sale of shares of the capital stock of the Pampanga Sugar Mills was negotiated, perfected, and consummated in San Francisco, California.

ISSUE: May our Government impose income tax on said sale?

HELD: No, since all the factors (negotiation, perfection and consummation) took place in California, said place is deemed to be the source of the capital gain. Therefore, this is income derived from abroad. Under our present laws, only corporate income derived from Philippine sources may be taxed in our country.

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