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In the Matter of Declaratory Relief on the Validity of BIR Revenue Memorandum Circular No. 65-2012 (Taxability of Association Dues, Membership Fees and Other Assessments Collected by Condominium Corporations)

IN THE MATTER OF DECLARATORY RELIEF ON THE VALIDITY OF BIR REVENUE MEMORANDUM CIRCULAR NO. 65-2012 "CLARIFYING THE TAXABILITY OF ASSOCIATION DUES, MEMBERSHIP FEES AND OTHER ASSESSMENTS/CHARGES COLLECTED BY CONDOMINIUM CORPORATIONS" G.R. No. 218924 BUREAU OF INTERNAL REVENUE (BIR), AS HEREIN REPRESENTED BY ITS COMMISSIONER KIM S. JACINTO-HENARES AND REVENUE DISTRICT OFFICER (RDO) RICARDO B. ESPIRITU, PETITIONER, VS. FIRST E-BANK TOWER CONDOMINIUM CORP., RESPONDENT. IN THE MATTER OF DECLARATORY RELIEF ON THE VALIDITY OF BIR REVENUE MEMORANDUM CIRCULAR NO. 65-2012 "CLARIFYING THE TAXABILITY OF ASSOCIATION DUES, MEMBERSHIP FEES AND OTHER ASSESSMENTS/CHARGES COLLECTED BY CONDOMINIUM CORPORATIONS" FIRST E-BANK TOWER CONDOMINIUM CORP., PETITIONER, VS. BUREAU OF INTERNAL REVENUE (BIR), AS HEREIN REPRESENTED BY ITS COMMISSIONER KIM S. JACINTO-HENARES,* RESPONDENT.

G.R. No. 218924 and G.R. No. 215801 | 2020-01-15

D E C I S I O N
 
LAZARO-JAVIER, J.:
 
The Cases

These twin cases refer to the: 1) Petition for Review filed by the Bureau of Internal Revenue (BIR) (G.R. No. 215801); and 2) Special Civil Action for Certiorari initiated by the First E-Bank Tower Condominium Corp. (First E-Bank) (G.R. No. 218924). Both cases assail the following dispositions of the Court of Appeals in CA-G.R. CV No. 102266 entitled "In the Matter of Declaratory Relief on the Validity of BIR Revenue Memorandum Circular No. 65-2012 'Clarifying the Taxability of Association Dues, Membership Fees and Other Assessments/Charges Collected by Condominium...