Amendments and assessments: Revisiting the nature of substantial changes
Amendments and assessments: Revisiting the nature of substantial changes
In tax litigation, one of the first questions we ask when elevating an assessment from the Bureau of Internal Revenue (BIR) to the Court of Tax Appeals (CTA) is, “Was the assessment made within the prescriptive period?” This is because when prescription is properly established, we no longer have to argue on the other merits […]
In tax litigation, one of the first questions we ask when elevating an assessment from the Bureau of Internal Revenue (BIR) to the Court of Tax Appeals (CTA) is, “Was the assessment made within the prescriptive period?” This is because when prescription is properly established, we no longer have to argue on the other merits […]