ReSA - THE REVIEW SCHOOL OF ACCOUNTANCY

CPA Review Batch 50  October 2025 CPA Licensure Examination

TAX-801
TAXATION Prepared By: A. S. TAMAYO
For TeamTax: A. TAMAYO  G. CAIGA  E. GARCIA  C. LIM  K. MANUEL  J. TAGLE

SOURCES of INCOME
1. Classification of Income as to Sources
a. Income purely within
b. Income purely without
c. Income partly within and partly without

2. Determination of Income as to Sources

ITEMS OF INCOME TEST OF SOURCE OF INCOME
a. Interest Residence of the debtor
b. Dividends
1) From domestic corporation Income within
2) From foreign corporation Income within unless less than 50% of the gross income of such
foreign corporation for the 3-year preceding the declaration of
such dividends or for such part of such period as the corporation
has been in existence was derived from sources within the
Philippines as determined under the provision of this Section, but
only in an amount which bears the same ratio to such dividends
as the gross income of the corporation for such period derived
form sources within the Philippines bears to its gross income from
all sources. [Sec. 42(2)(b)], NIRC
c. Income from services Place of performance
d. Rent Location of property
e. Royalties Place of use of intangibles
f. Gain on sale of real property Location of property
g. Gain on sale of personal property
purchased in one country and sold in
another Place of sale
h. Gain on sale of domestic shares Income within

3. Deductions of Taxpayers Whose Taxable Income Is From Philippine Sources Only

Gross income within xxx
Less: Expenses, interest, losses and other deductions properly allocated to income within xxx
Ratable portion of unallocated expenses, interest, etc.
(Philippine Gross Income/Total gross income x Unallocated expenses) xxx xxx
Net income xxx
4. Exercise
A corporation has the following income and expenses for the current year:
Gross income, Philippines P1,600,000
Gross income, USA 400,000
Business expenses, Philippines 500,000
Business expenses, USA 200,000
Unallocated business expenses 150,000
Interest expense, USA 50,000
Interest expense, Philippines 100,000
Unallocated interest expense 80,000
Total assets excluding the land 50,000,000

Compute the tax due and payable assuming the above corporation:
a. Resident foreign corporation. c. Domestic corporation
b. Nonresident foreign corporation.

5. Income partly from sources within and partly from sources without
a. Examples a. Income from transportation and other services rendered partly within and partly
without the Philippines.
b. Income from the sale of personal property produced in whole or in part by the
taxpayer within and sold without the Philippines.
c. Income from sale of personal property produced, in whole or in part by the taxpayer
without and sold within the Philippines.

b. Computation of Taxable income x Value of property, within_________

income within when 2 Value of property, within and without xxx
independent factory Add:
or production price Taxable income x Gross sales, within_____
has not been 2 Gross sales, within and without xxx
established Income within xxx

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ReSA – THE REVIEW SCHOOL OF ACCOUNTANCY
SOURCES of INCOME TAX-801
6. Exercises
a. A corporation manufactures goods in the Philippines, which are sold exclusively in foreign countries.
The following data are taken from the records of the corporation:
Gross sales, without P5,000,000
Gross income from sales, without 3,000,000
Operating expenses 2,100,000
Value of properties, Philippines 300,000
Value of properties, without 600,000

Determine the taxable income within and without.

b. An individual taxpayer has the following data on income and expenses in 2022:
1) Gross business income, Philippines P220,000
2) Rent on building, Philippines, net of 5% withholding tax 95,000
3) Rent on commercial building, USA 90,000
4) Interest income, debtor resides in Hongkong 30,000
5) Dividends from Ford Motors, foreign company, declared in 2022 60,000
Note: Gross income of Ford Motors follows:
Within Without
2019 P300,000 P500,000
2020 400,000 100,000
2021 500,000 200,000
2022 350,000 150,000
6) Royalties received from Ford Motors for use of patents in USA 30,000
7) Dividend from Walmart Corp., USA, declared in 2022 80,000
Note: Gross income of Walmart for the preceding 2 years prior to declaration of
dividend follow:
Within Without
2020 P400,000 P600,000
2021 200,000 400,000
8) Gain on sale, Philippines, land located in Japan 350,000
9) Gain on sale, Philippines, car purchased in Japan 40,000
10) Expenses:
a) Business expenses, Philippines 100,000
b) Depreciation building in Philippines 20,000
c) Depreciation building in USA 10,000
d) Expenses, sale of car in the Philippines 10,000
e) Expenses, sale of land in the Philippines 50,000
f) Unallocated expenses 60,000

REQ: a. Classify income into income within and income without.

b. Determine the taxable income/subject to final withholding tax assuming the individual taxpayer
is:
1) NRA- ETB, single, (his country allows P40,000 personal exemption to single Filipinos not
residing in his country.)
2) NRA-NETB, head of family.
3) Resident, married with two qualified dependent children.

END

THOT: “God gave each one of us talents, it is up to us whether to bury them or to enrich them.”
-Tamthewise

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