INCOME TAX - Susan Dajao Tusoy

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INCOME TAX
Presented by:
LILYBETH A. GANER, CPA, MBA
Revenue Officer
RR-19, Davao City
1
Business Income
 Any income not related to an employeremployee relationship
 Generally taxable on the net income
 Includes gains, profits and income in
whatever form derived from any source,
legal or illegal, such as –






Exercise of profession or vocation
Trade, business or commerce
Dealings in property
Fruits of the ownership or use of property
Interest, rent, dividends, securities
Other transactions of the business for gain or
profit
2
Gross income
 All income from whatever source
derived, including but not limited to
the following items:
 Compensation for services, including
fees, commissions and similar items
 Gross income derived from business or
exercise of profession
 Gains from dealings in property
 Interest
 Rents
3
Gross income (cont.)






Royalties
Dividends
Annuities
Prizes and winnings
Pensions
Partner’s distributive share in the net
income of general professional
partnership
4
Net Income
 The realized gross profit after deducting all the
deductions allowed by law, statutes or generally
accepted accounting principles.
Exclusions
 The total benefits which is not included in the
computation of gross income for the purpose of
determining taxable income.
Deductions
 Items or amounts which the law allows to be
deducted from gross income to arrive at the taxable
income.
5
Allowable Deductions
 There shall be allowed as deduction
from gross income, other than
compensation income, expenses
incurred in the conduct of trade or
business to arrive at the net income.
 At the taxpayers option, deductions
for expenses may either be—
 Itemized deduction
 Optional Standard Deduction (OSD) –
40%
6
Requisites for Deductibility of Expenses
Ordinary and necessary
Paid or incurred within the taxable year
Incurred in the conduct of trade or business
Not contrary to law, morals, public policy or
public order
 Substantiated by sufficient proof
 Subjected to withholding tax, if applicable




7
Itemized Deduction
1. Ordinary and necessary trade,
business or professional expenses




Salaries & wages
Travel expenses
Rental expenses
Entertainment, amusement and
recreation expenses
2. Interest
3. Taxes
8
Itemized Deduction (cont.)
4. Losses
 Net Operating Loss Carry Over (NOLCO)
 Capital losses
 Losses from wash sales of stocks or
securities
 Wagering losses
 Abandonment losses
9
Itemized Deduction (cont.)
5. Bad debts
6. Depreciation
7. Depletion of oil and gas wells and
mines
8. Charitable and other contributions
9. Research and development
10.Pension trusts
10
Interest
 There must be a valid and existing
indebtedness;
 The indebtedness must be that of the
taxpayer;
 The interest must be legally due and stipulated
in writing;
 The interest expense must be paid or incurred
during the taxable year;
 The indebtedness must be connected with the
taxpayer's trade, business or exercise of
profession;
12
Interest
 The interest payment arrangement must not
be between related taxpayers.
 The interest is not expressly disallowed by
law to be deducted from the taxpayer’s
gross income (e.g., interest on indebtedness
to finance petroleum operations); and
 The amount of interest deducted from gross
income does not exceed the limit set forth in
the law.
13
Interest
 Limitation
The amount of interest expense paid or incurred
from an existing indebtedness shall be reduced by an
amount equivalent the following percentages of the
interest income earned during the year which had
been subjected to final withholding tax
Jan. 1998
Jan. 1999
Jan. 2000
Nov 2005
Jan. 2009
-
41%
39%
38%
42%
33%
Applies regardless of the date the
interest bearing loan and the date
when the investment was made for
as long as, during the taxable year
there is an interest expense
incurred and an interest income
earned.
14
Interest
EXCEPTIONS
• Deductible in full from gross income
Interest on unpaid taxes – interest paid or incurred on all unpaid
business-related taxes shall be deductible in full
• Not deductible from gross income
a. Interest incurred on indebtedness of taxpayer using cash basis,
where the interest is paid in advance thru discount or otherwise
i. Allowed as a deduction in the year the indebtedness was paid
ii. If amortized – amount corresponding to the principal
amortized shall be allowed as deduction during the year
15
Interest
•
Not deductible from gross income
b. Interest payments between related parties as
specified in Sec. 36(B) of the Tax Code
c. Interest expense paid or incurred by Service
Contractor engaged in the discovery or production
of indigenous petroleum in the Phil.
d. Interest incurred on capital expenditures (optional)
• Interest expense
• Capital expenditure
16
Interest
RELATED PARTY TRANSACTIONS
[Sec. 36(B)]
• Between members of the same family
• Between a corporation and an individual who owns more than
50% of the outstanding stock of the former
• Between 2 corporations more than 50% of the outstanding
stock were owned by the same individual
• Between grantor and fiduciary of any trust
• Between 2 fiduciaries of trust if the same person is the
grantor of each trust
• Between fiduciary and beneficiary of the same trust
17
Taxes
 All business related taxes
 Non-deductible taxes
 Income tax paid in the Phils.
 Income tax imposed by authority of foreign
country – tax credit with limitation
 Estate and donor’s taxes
 Tax assessment which increases the value of the
property assessed
 Electric energy consumption tax under B.P. 36
 VAT
 Tax credits
 Taxes paid in foreign countries subject to
limitation
18
Taxes
 Interest or surcharge imposed on taxes are not
deductible as taxes, but as an item of interest.
 Only the person upon whom taxes are imposed
may claim them as deduction, except: (1)
Taxes upon an individual upon his interest as
shareholder of corporation which are paid by
corporation without reimbursement; and (2)
Corporate bonds or other obligations containing
a tax-free covenant clause, the corporation
paying the tax or any part of it for someone
else (Sec. 80, RR 2).
19
Taxes
 Refund of tax payment
 Taxes refunded shall be included in the
year of receipt to the extent of the income
tax benefit of such deduction (tax benefit
rule)
20
Taxes
Disclosure requirement on taxes
(Notes to FS) RR 15-2010
 The notes of f/s shall include info on
taxes, duties and license fees paid or
accrued during the taxable year
The amount of VAT Output tax and the
account title and amount/s upon which the
same was based,
21
Losses
 Requisites for deductibility
 Incurred in trade, business or profession
 Not compensated by insurance or other form of
indemnity
 In case of property, for losses arising from fire,
storm, shipwreck, other casualty, robbery, theft,
embezzlement, the property must be used in
trade, business or profession and reported
within forty-five (45) days from date of
occurrence of such loss.
 Not claimed as deduction for estate tax
purposes
22
Net Operating Loss Carry-over
(NOLCO) RR 14-2001
 Net operating loss - means the
excess of allowable deduction over gross
income of the business in a taxable year
23
Bad Debts
 Requisites for valid deduction
 There must be an existing indebtedness due to
the taxpayer
 It must be valid and legally demandable
 It must be connected with the taxpayer’s trade,
business or practice of profession
 It must not be sustained in a transaction entered
into between related parties
 It must be actually charged off from the books of
accounts as of the end of the taxable year
 It must be ascertained to be worthless and
uncollectible as of the end of the year
24
Depreciation
 A reasonable allowance/reduction in service
value for the exhaustion, wear and tear of
property used in trade, business or practice
of profession.
 Methods of depreciation




Straight line method
Declining balance method
Sum of the year’s digit method
Any other method which may be prescribed
25
Depreciation
Requirements for deductibility
 The allowance for depreciation must be
reasonable;
 It must be for property arising out of its
use in the trade or business, or out of its
not being used temporarily during the
year; and
 It must be charged off during the taxable
year from the taxpayer’s books of
accounts.
26
Charitable and other Contributions
 Donations with limited deductibility
 For the use of government exclusively for public
purpose
 To accredited domestic corporation or
association organized and operated exclusively
for religious, charitable, scientific, youth and
sports development, cultural or educational
purposes
 For the rehabilitation of veterans
 For social welfare institutions
 To non-government organization
27
Charitable and other Contributions
 Rate of deduction
 Individual donor
-
10% of net income
before deducting
donations
 Corporate donor
-
5% of net income before
deducting donations
OR
Actual contribution/donation
WHICHEVER IS LOWER
28
Charitable and other Contributions
 Donations deductible in full
 Donations to the government exclusively to
finance or to be used in undertaking priority
activities in education, health, youth and sports
development, human settlements, science and
culture and in economic development according
to the National Priority Plan determined by
NEDA.
 Donations to foreign institution or international
organizations
 Donations to accredited non-government
organizations
29
Entertainment, Amusement &
Recreational (EAR) Expenses
 Includes representation expense and/or
depreciation or rental expense relating to
entertainment facilities.
 Representation expense shall refer to
expenses incurred in entertaining,
providing amusement and recreation to, or
meeting with guest or guests at dining
place, place of amusement, country club,
theater, concert, play, sporting event and
similar events or places.
30
Entertainment, Amusement &
Recreational (EAR) Expenses
 Expenses NOT considered EAR
 Expenses treated as compensation or fringe benefits
 Expense for charitable or fund raising events
 Expense for bonafide business meeting of
stockholders, partners or directors
 Expenses for attending or sponsoring employee to a
business league or professional organization
meeting
 Expenses for events organized for promotion
marketing and advertising including concerts,
conferences, seminars, workshops, convention, and
other similar event.
 Other expense of similar nature
31
Entertainment, Amusement &
Recreational (EAR) Expenses
 The taxpayer should maintain receipts and
adequate records that indicate the
The amount of expense
Date and place of expense
Purpose of expense
Professional or business relationship of
expense
 Name of person and company entertained
with contact details




32
Entertainment, Amusement &
Recreational (EAR) Expenses
 Requirements for deductibility
 Paid or incurred during the taxable year
 Business connected
 Not contrary to law, morals, good customs,
public policy or public order
 Does not constitute a bribe, kickback or
other similar payment
 Duly substantiated by adequate proof
 Subjected to withholding tax, if applicable
33
Entertainment, Amusement &
Recreational (EAR) Expenses
 Imposition of Ceiling [Sec. 34(A)(1)(a)(iv) of NIRC)
& RR 10-2001]
Actual entertainment, amusement and recreation expense
OR
 .5% of net sales for sellers of goods and properties
 1% of net revenues for sellers of services
WHICHEVER IS LOWER
34
TAXPAYER ENGAGED IN BOTH
SALE OF GOODS AND SERVICES
Allowable EAR expense shall be determined based on
apportionment formula –
Percentage of net sales/net revenue to the total net sales/net
revenue multiplied by the actual EAR expense
Net sales/net revenue
Total net sales/revenue
x Actual expense
Note:
In no case shall the total EAR exceed the maximum percentage ceiling
35
Illustration:
ERA Corporation is engaged in the sale of goods and
services with net sales/net revenue of P200,000 and
P100,000 respectively. The actual EAR for the year 2010
totaled P3,000
Computation:
*Apportionment formula
Sale of goods (P200,000/P300,000) x P3,000 = P2,000
Sale of service (P100,000/300,000) x P3,000 = P1,000
**Maximum percentage ceiling
Sale of goods P200,000 x 0.50% = P1,000
Sale of service P100,000 x 1%
= P1,000
36
Computation:
Net sales/
net revenue
EAR expense
based on
apportionment
formula*
Maximum
percentage
ceiling of
EAR**
Allowable
amount to
be claimed
as EAR (w/c
ever is
lower)
Sale of
goods
P200,000
P2,000
P1,000
P1,000
Sale of
services
P100,000
P1,000
P1,000
P1,000
Total
P300,000
P3,000
P2,000
P2,000
ERA Corporation can only claim a total of P2,000 as EAR
37
Optional Standard Deduction
In lieu of the itemized deductions enumerated under
Sec. 34(A) to (J) and (M) and Sec. 37 of the Tax
Code and other special laws (if applicable) .
38
Optional Standard Deduction
 Individuals
 Resident citizen
 Non-resident citizen
 Resident Alien
 Taxable estates and trusts
 Corporations (subject to normal income tax rate)
 Domestic corporation
 Resident foreign corporation
39
Optional Standard Deduction
Individual
Corporation
Rate
40% of gross
sales/revenues
40% Gross
income
Tax Base
Excluding
passive income
subject to final
withholding tax
Excluding
passive income
subject to final
withholding tax
Cost of
sales/services
Not allowed to
deduct
COS/services
Allowed to
deduct
COS/services
40
Optional Standard Deduction
 Disclosure of election to use the OSD
(RMC 16-2010)
 Taxpayers availing of the OSD are
required to check the appropriate box in
the ITR for the first quarter of the
taxable year 2009.
 Failure to indicate the election to avail of
the OSD shall be considered as having
availed of the itemized deduction.
43
Optional Standard Deduction
 Disclosure of election to use the OSD
(RMC 16-2010)
 The same type of deduction must be
consistently
applied
for
all
the
succeeding quarterly returns and in the
final ITR for the taxable year.
 New registrants shall disclose their
election to avail OSD in their initial
quarterly ITR.
44
Optional Standard Deduction
 Implication of OSD
 Option is irrevocable for the taxable year
for which the return is made.
 Any subsequent amendment of ITR filed for
the first/initial quarter shall not affect the
irrevocable character of the election to avail
of the OSD or itemized deduction.
 Individual claiming the OSD is not required
to submit financial statements but shall
keep records of his gross sales/receipts
45
Illustration 1
Mr. Era , a retailer of goods uses the accrual method of
accounting in reporting his income and expenses. For
the year 2010, the following are his recorded income
and expenses
Gross sales
Jan-June
July-Sept
Oct-Dec
P1,000,000
700,000
900,000
Cost of
sales
P600,000
200,000
400,000
Operating
exp
P50,000
100,000
Mr. Era uses the OSD as indicated on his 1st quarter
ITR. Compute for the allowable deductions for each of
the quarters of 2010 and the net income for the
taxable year.
46
Computation 1
a) Allowable deductions
Jan. – June
Gross sales
P1,000,000
Less: Cost of sales
-0Gross sales/income
P 1,000,000
X OSD rate
40%
OSD
P 400,000
======
July – Sept
P700,000
-0P700,000
40%
Oct - Dec
P900,000
-0–
P900,000
40%
P280,000
=======
P360,000
=======
b) Net income for 2010
Gross sales (Jan – Dec)
OSD (40%)
Net income
P2,600,000
1,040,000
1,560,000
========
47
Illustration 2
GSV Corporation, a retailer of goods, uses the accrual
method in declaring its income and expenses. For the
calendar year 2010, the following are the records of its
income and expenses:
Gross sales
Jan-June
July-Sept
Oct-Dec
P1,000,000
700,000
900,000
Cost of
sales
P700,000
300,000
600,000
Operating
exp
P100,000
200,000
100,000
GSV Corp. uses the OSD. Compute for the quarterly
allowable deductions (cost and expenses) and the net income
for 2010.
48
Computation 2
a) Allowable deduction
Jan – June
Gross sales
P1,000,000
Less Cost of sales
700,000
Gross income
300,000
X OSD rate
40%
OSD/Operating expenses P120,000
Add: Cost of sales
700,000
July – Sept
P700,000
300,000
P400,000
40%
P160,000
200,000
Oct – Dec
P900,000
600,000
P300,000
40%
P120,000
100,000
Total deductions
P360,000
=======
P220,000
=======
b) Net income
Gross sale
Cost of sales
Gross income
OSD (40%)
Net income
P820,000
=======
P2,600,000
1,600,000
1,000,000
400,000
P 600,000
=======
49
Taxation of Mixed Income
 It follows the compartmentalized approach
for returnable income.
 Personal exemptions are first deducted
from compensation income.
 Excess of PE over compensation income are
deductible from net income from business.
 Separate computation of income tax liability
for husband and wife.
 Only one spouse will claim additional
personal exemption.
50
50
Taxation of Mixed Income
 Taxable compensation income is added to
taxable income from business and the
aggregate taxable income is subjected to
the graduated tax rates.
 Loss from business can not be offset
against compensation income but can be
carried over as NOLCO.
 One consolidated income tax return for
husband and wife.
 Pay-as-you-file, but installment is allowed if
tax due exceeds P2,000 [Sec. 56(A)(2)].
51
Taxation of
Marginal Income Earners
(RR 11-00)
 Individuals not deriving compensation income
 Self-employed
 Deriving gross sales/receipts not exceeding
P100,000 during any 12-month period
 Principally earning for subsistence or livelihood
 Exempt from VAT and any percentage tax
 Not required to pay the registration fee
 Required to register as taxpayer
 Exempt from the invoicing requirements
52
Taxation of
Marginal Income Earners
(RR 11-00)
 Exempt from maintaining books of accounts
 Required to file the Annual Income Tax Return
(Form 1700) but not required to attach
Financial Statements or Account Information
Form to the filed ITR
 May or may not be liable to tax
53
Income Tax Computation
Corporate Taxpayer
54
What is a corporation?
Corporation – is an artificial being created by law, having
the rights of succession and the powers, attributes and
properties authorized by law or incident to its existence.
For taxation purposes, corporation shall include –
 Partnerships
 Joint-stock companies
 Joint accounts
 Associations
 Insurance companies
55
A corporation does not include –
•General Professional Partnership
•Joint venture or consortium formed for the
purpose of undertaking construction projects
or engaging in petroleum, coal, geothermal
and other energy operations pursuant to an
operating or consortium agreement under a
service contract with the government
56
MINIMUM CORPORATE INCOME TAX
(MCIT)
RR No. 9-98, as amended by RR no. 12-07
57
Sec. 27(E) and 28 (A)(2) of the NIRC
Imposed on:
Domestic & Resident Foreign
2% on Gross Income
if: - in the 4th year of operation
- net loss/zero taxable income/
MCIT is greater than NCIT
58
Gross income
Include all items of gross income enumerated under Section
32(A) of the Tax Code, as amended, except income exempt from
income tax and income subject to final. withholding tax.
For Sale of goods
Gross sales – (cost of goods sold + sales returns +
discounts+ allowances)
“Gross sales”
Include only sales contributory to income taxable under Sec.
27(A) of the Code.
“Cost of goods sold”
Include all business expenses directly incurred to produce the
merchandise to bring them to their present location and use.
59
For sale of services
Gross revenue – (cost of services/direct cost + sales
returns + discounts + allowances)
“Gross Revenues”
Include income from sale of services, likewise, taxable
under Sec. 27(A)
“Cost of services or Direct cost of Services”
Include all business expenses directly incurred or related
to the gross revenue from rendition of services.
60
Illustration
Gross sales/ revenues
1,000,000.00
Less: Sales Ret., Disc & Allow.
25,000.00
Cost of Goods Sold/ services
500,000.00
Gross Income from operation
475,000.00
Add: Other Income not subject to
Final Tax or Capital Gains Tax
100,000.00
Total Gross Income subject to MCIT 575,000.00
========
61
Carry forward of Excess MCIT
• Excess of MCIT over normal income tax shall be
carried forward on an annual basis and credited
against the normal income tax for the 3 immediately
succeeding taxable years.
• Excess MCIT can only be credited against the
income tax due if the normal income tax is higher
than the MCIT
62
Carry forward of Excess MCIT
• Excess MCIT which has not or cannot be so
credited against the normal income tax due
for the 3-year period shall lose its credibility.
• Excess MCIT cannot be claimed as a credit
against the MCIT itself or against any other
losses
63
Carry forward of Excess MCIT
• The final comparison between the normal
income tax payable and the MCIT shall be
made at the end of the taxable year.
• The payable or excess payment in the
Annual Income Tax Return shall be
computed taking into consideration income
tax payment made at the time of filing of
quarterly income tax returns whether this be
MCIT or normal income tax
64
Suspension of MCIT
•
Instances when MCIT may be suspended
Substantial losses on account of –
 Prolonged labor dispute
 Force majeure
 Legitimate business reverses
•
Who may suspend
 Secretary of Finance upon
recommendation of the CIR
65
Suspension of MCIT
•
Required documentation
 Submission of proof by the corporation
 Duly verified by the CIR’s duly authorized
representative
66
IMPROPERLY ACCUMULATED
EARNINGS TAX
(IAET)
RA 8424/ RR No. 2-2001/RMC 35-2011
67
CONCEPT OF IAET
• Taxpayer is a corporation
• Improper accumulation of taxable income beyond
the reasonable needs of the business
• Non-distribution of earnings/profits to stockholders
• The purpose of accumulation is to avoid the
payment of the income tax
• Imposition of tax equivalent to 10% of the
improperly accumulated taxable income
• The tax imposed is in the nature of penalty to a
corporation for improper accumulation of earnings
beyond the reasonable needs of the business
68
EVIDENCE OF PURPOSE TO AVOID
THE TAX
• The corporation is a mere holding or
investment company
• Earnings or profits are permitted to
accumulate beyond the reasonable
needs of the business
69
Reasonable vs. Unreasonable Accumulation
 Reasonable Needs of Business:
 Immediate needs of business, including
reasonably anticipated needs (Immediacy
Test)
 Unreasonable Accumulation
 Not necessary for the purpose of the
business considering all circumstances of
the case
70
Reasonable Needs of Business
 100% of the paid up capital or the amount
contributed to the corporation representing
the par value of the shares of stock, hence,
any excess capital over & above the par shall
be excluded (RMC 35-2011).
71
Reasonable Needs of Business
 Earnings Reserved
 for definite corporate expansion projects
 for building, plant or equipment acquisition
 for compliance with loan covenant or preexisting obligation established under a
legitimate business agreement.
 Required by law to be retained or with legal
prohibition
 In case of foreign corporation subsidiaries,
intended for investments within the
Philippines
72
Unreasonable accumulation of Profits
 Investment of substantial earnings and
profits of the corporation in unrelated
business or in stock or securities of
unrelated business;
 Investment in bonds and other long term
securities; and
 Accumulation of earnings in excess of
100% of paid-up capital or contribution
representing the par value of the shares
of stock.
73
Corporation Exempt from IAET







Banks and non-bank financial intermediaries
Insurance companies
Publicly held corporations
Taxable partnerships
GPP
Non-taxable joint ventures
Firms registered under RA 7916, 7227, and other
special ecozones
74
IMPOSITION OF IAET
Tax rate
10%
Corporations liable
Closely-held domestic
corporations
Deadline
15th day after the
end of he year following the
close of the taxable year
75
Closely-held corporations:
 are corporations at least 50% in value
of the outstanding capital stock or at
least 50% of the total combined
voting power of all classes of stocks
entitled to vote is owned directly or
indirectly by or for not more than 20
individuals
76
TAX BASE OF IAET
(Improperly Accumulated Taxable Income)
Taxable income
Add:
(a) Income subject to final tax
(b) NOLCO
(c) Income exempt from tax
(d) Income excluded from gross income
Total
Less: Income tax paid for the year
Div. actually or const. paid/issued
Total
Less : Amount that can be retained
IATI
P xxx
Pxxx
xxx
xxx
xxx
xxx
xxx
xxx
P xxx
xxx
xxx
xxx
Pxxx
===
77
Payment of IAET
 Dividend must be declared and paid not later
than one year following the close of the taxable
year
 Otherwise, IAET should be paid within 15 days
thereafter
Once the profit has been subjected to IAET, the same shall no
longer be subjected to IAET in later years, even if not declared as
dividend.
Profits subjected to IAET, when finally declared as dividends, shall
be nevertheless be subject to 10% final withholding tax
78
Income Tax Forms and
Due Dates
79
Income Tax Forms
Form
No.
1702
Form Name
Annual Income Tax
Return
(For Corporations,
Partnerships and
Other Nonindividual
Taxpayers)
Deadline for Filing
On or before April
15
No. of
Copies
3 copies
On or before the
15th day of the 4th
month following
the close of the
fiscal year
80
Form
No.
1702Q
1704
Form Name
Quarterly Income Tax
Return
(For Corporations,
Partnerships and Other
Non-individual
Taxpayers)
Improperly
Accumulated Earnings
Tax Return
Deadline for Filing No. of Copies
60 days
following the
close of the first
3 taxable
quarters
3 copies
On or before the
15th day of the
following year
following the
taxable year
3 copies
81
NOTE:
Installment Payments
• Applicable to individual taxpayer
only and NOT TO CORPORATION
next
82
New Income Tax Forms
Presented by:
LILYBETH A. GANER
Revenue Officer
ASSESSMENT DIVISION
RR 19-DAVAO CITY
Revised Forms
 BIR Form 1700 ( Purely Compensation
Income )
 BIR Form 1701 (Self-Employed
Individual,
Estate and
Trust)
 BIR Form 1702 ( Corporations,
Partnership and Other Non- Individual
Taxpayer
Effectivity
-Income tax filing covering and starting with calendar
year
2011, due for filing on or before April 15. 2012
- Juridical entities on FY basis are to use
starting with those FY ending January 31, 2012
Features
 To be read by an optical character
reader
 Use Nov. 2011 version
 Box Type
 Shading
 All information must be written in
capital letters
 Orientation is landscape (horizontal)
 e-mail address of taxpayer
features
 Field No. 47 – for filer’s new address
 With supplemental information
(optional)
 Schedule of gross income subjected to
final tax
 Schedule of gross income/receipts exempt
from income tax
“Knowing is not enough; we must apply.
Willing is not enough; we must do.”
Johann Wolfgang von Goethe
88
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