Tax 102 – Business and Transfer Tax

Prepared by: Mark Paul I. Ramos

MODULE 7.1
Estate Taxes

INTRODUCTION
This module introduces one of the Transfer Taxes under the Tax Code: the Estate
Taxes. This chapter explains what transfer taxes are, what is the difference between estate
tax and donor’s tax. The basic concepts of succession and will also be discussed. Another
topic that will be tackled is the properties included in a decedent’s estate.

INTENDED LEARNING OUTCOMES

ILO 1 – Understanding transfer taxes: estate tax and donor’s tax
ILO 2 – Recognizing basic concepts of succession and will
ILO 3 – Analysis of the rulings in relation to succession, properties subject to estate tax

Introduction to Transfer tax

Transfer tax is a tax imposed upon the gratuitous transfer of property ownership. It is
a privilege tax which is imposed on the act of passing ownership of property and not a tax on
the property itself (Domondon, Bar Reviewer in Taxation, Vol 2, p448).

The transfer of ownership may take effect during the lifetime (donor’s tax), or upon
the death of a person (estate tax).

The transfer taxes defined in the NIRC are the following:

1. Estate tax – an excise tax imposed upon the right of transmitting property at the
time of death, and the privilege of controlling the disposition of one’s property to
take effect upon death; and
2. Donor’s (Gift) tax – a tax on the privilege of transmitting one’s property to another
during his lifetime without adequate and full valuable consideration.

Estate tax and Donor’s tax

1. Estate tax is a tax imposed on the privilege to transmit property upon one’s death
while donor’s tax is a tax imposed upon one’s privilege to transfer property during
lifetime.
2. The rates in estate tax and donor’s tax are the same at six percent (6%).
3. In estate tax, extensions for filing and payments including payment of tax by
installments are allowed, while in donor’s tax these are not allowed.
4. The exemption from donor’s tax per year is P250,000 of net gift, while in estate tax
there is no exemption.

ILLUSTRATION Rocky Fuller gave P500,000 worth of property to his son Ricky and
P200,000 cash to his niece, Rica. Indicate if the transfer of the property
is subject to donor’s tax or to estate tax if:

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a. The donation is made during the lifetime of the donor.

b. The donation is provided in his will.

ANSWER a. If the donation is made during the lifetime of the donor, then it is in
the nature of a donation inter vivos. Therefore, it is subject to donor’s
tax.

b. If the donation is provided in the will, then the transfer of the

ownership will take place only upon the death of the donor. Therefore,
it is a mortis causa donation which is subject to estate tax.

Effect of misnomer on the instrument

The nature of a donation is not determined by the title given to it by the donor, but by
what is expressed therein. The donor may entitle his donation as one “mortis causa,” but if it
is in reality a donation inter vivos, its validity and revocability will be determined by the rules
for the latter kind of donations. On the other hand, the donation may be termed “inter vivos”
by the donor, but if it is essentially a disposition mortis causa, it will be held void if not made
in the form and with the solemnities of a will (Tolentino, supra).

Introduction to Estate Tax

Estate tax is a tax on the right of the decedent person to transmit his/her estate to
his/her lawful heirs and beneficiaries at the time of death, and on certain transfers which are
made by law as equivalent to testamentary disposition.

Estate tax is levied upon the transfer of the net estate of a decedent to his heirs
(Sec84, NIRC).

It is an excise tax because it is imposed upon on the exercise of the right to transfer
ownership over the property. It is not a tax on the property transferred.

The estate tax accrues at the moment of death of the decedent (Lorenzo vs
Posadas, 64 Phil 353; Beam vs Yatco, 28 Phil 30).

Moreover, the law in force at death of the decedent is controlling, notwithstanding

postponement of the actual possession or enjoyment of the property by the beneficiary
(supra).

Theories justifying the imposition of estate tax

Estate tax is imposed primarily to raise revenue for public purposes or for the support
of the government.

Moreover, the following theories have been identified to justify the imposition of
estate tax:
1. Benefit-received theory – a tax is collected by the state because the latter
renders services in the distribution of the decedent’s estate, either by law or in
accordance with his will.

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2. Privilege theory (State Partnership theory) – succession to the property of a

deceased is not a fundamental right but a privilege granted by the state.
Consequently, the state, as a “silent and passive partner” in the accumulation
of property can collect the share which is due to it.
3. Redistribution of wealth theory – the imposition of a estate tax will result to a
more equitable distribution of wealth in the society.

Computation of estate tax

The computation of the estate tax will depend on the status of the decedent, whether
he was single or married.

1. Decedent was single, unmarried or legally separated at the time of death:

Gross estate xxx

Less: Deductions
Ordinary xxx
Special xxx xxx
Taxable net estate xxx
Multiply by tax rate 6%
Estate tax due xxx
Less: Tax credit xxx
Estate tax payable xxx

2. Decedent was married at the time of death:

Conjugal/
Communal Exclusive TOTAL
Real properties xxx xxx
Personal properties xxx xxx
Gross estate xxx xxx xxx
Less: Ordinary deductions
Claims against the estate xxx xxx
Claims of the deceased against insolvent
persons xxx xxx
Unpaid mortgages, taxes and losses xxx xxx
Vanishing deduction xxx xxx
Transfer for public use - xxx xxx
Estate after ordinary deductions xxx
Less: Special deductions
Standard deduction xxx
Family home xxx
RA 4917 xxx
Net Estate xxx
Less: Share of surviving spouse in the net conjugal/
communal property xxx
Taxable net estate xxx
Multiply by tax rate 6%

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Estate tax due xxx

Less: Tax credits xxx
Estate tax payable xxx
a. SUCCESSION
Basic concepts of succession and will
Succession is a mode of acquisition by virtue of which the property, right and
obligations to the extent of the value of the inheritance, of a person are transmitted through
his death to another or others by will or by operation of law (Art 774, Civil Code of the
Philippines).

Elements of succession
1. Decedent – the person whose property is transmitted through succession, whether or
not he left a will.
2. Heir – the person called to the succession either by provision of a will or by operation
of law.
3. Estate – refers to all the property, rights and obligations of a person which are not
extinguished by his death

ILLUSTRATION Alicia died leaving a five-hectare coconut land to son, Boboy. Identify
the three elements of succession.

Kinds of succession
1. Testamentary – succession which results from the designation of an heir, made in a
will executed in the form prescribed by law
2. Legal or intestate – transmission of properties where there is no will, or if there is a
will, the same is void or nobody succeeds in the will
3. Mixed – transmission of properties which is effected partly by will and partly by
operation of law

Kinds of successors in a testamentary succession

1. Legatee – an heir to a particular personal property given by virtue of a will
2. Devisee – an heir to a particular real property given by virtue of a will

Persons authorized to manage the estate

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1. Executor – the person nominated by the testator to carry out the directions and
requests in his will and to dispose of his property according to his testamentary
provisions after his death
2. Administrator – a person appointed by the court, in accordance with the governing
statute, to administer and settle intestate estate and such testate estate as no
competent executor by the testator.
As a matter of distinction, an executor is appointed in the will while an
administrator is appointed by the court.

Time of succession
The rights to the succession are transmitted from the time of death of the decedent.

B. WILL
A will is an act whereby a person is permitted with the formalities prescribed by law,
to control to a certain degree the disposition of his estate, to take effect after his death.

Disqualifications to make and to witness a will

All persons who are not expressly prohibited by law may make a will. The persons
prohibited by law to make a will are those below 18 years of age and of those who are not of
sound mind at the time of execution.

Two or more persons cannot make a will jointly, or in the same instrument, either for
their reciprocal benefit or for the benefit of a third person.

The following are disqualified from being witnesses to a will:

a. Any person not domiciled in the Philippines
b. Those who have been convicted of falsification of a document, perjury or false
testimony.

Holographic will

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As a rule, every will must be acknowledged before a notary public by the testator and
the witnesses, in which it is called a notarized will.

However, the testator may make a will which wants to keep it secret which is known
as holographic will.

A person may execute a holographic will which must be entirely written, dated and
signed by the hand of the testator himself. It is subject to no other form, and may be made in
or out of the Philippines, and need not be witnessed.

Advantages and disadvantages of a holographic will

A holographic will has the following advantages:
a. easier to make
b. easier to revise
c. easier to keep secret

Although it has advantages, a holographic will has also some disadvantages, they
are:
a. easier to forge by expert falsifiers
b. easier to misunderstand since the testator may have been faulty in
expressing his last wishes
c. no guaranty that there was no fraud, force, intimidation, undue influence, and
no guaranty regarding testator’s soundness of mind.

In case of any insertion, cancellation, erasure or alteration in a holographic will, the

testator must authenticate the same by his full signature.

Revocation of will; codicil

A will may be revoked by the testator at any time before his death. Any waiver or
restriction of this right is void.

If after making a will, the testator makes a second will expressly revoking the first,
the revocation of the second will does not revive the first will, which can be revived only by
will or codicil.

A codicil is a supplement or addition to a will, made after the execution of a will and
annexed to be taken as a part thereof, by which any disposition made in the original will is
explained, added to, or altered.

No will shall be revoked except in the following cases:

1. by implication of law
2. by some will, codicil or other writing executed as provided in case of wills
3. by burning, tearing, canceling, or obliterating the will with the intention of
revoking it, by the testator himself, or by some other person in his presence,
and by his express direction.

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If burned, torn, cancelled, or obliterated by some other person, without the express
direction of the testator, the will may still be established, and the estate distributed in
accordance therewith, if its contents, and due execution, and the fact of its unauthorized
destruction, cancellation, or obliteration are established according to the Rules of Court.
Properties included in decedent’s estate
1. Properties that are still owned by decedent at the time of his death, to the extent of
his equity or interest in such property, whether as exclusive owner, conjugal or
community property owner, or common owner
2. Assets or properties owned by decedent during his lifetime but were no longer owned
by him at the time of his death, because these properties have been transferred
during his lifetime by way of taxable transfer as follows:
a. Transfer in contemplation of death
b. Revocable transfers
c. Property passing under the general power of appointment
d. Transfer for insufficient consideration.

The inheritance of a person includes not only the property and the transmissible
rights and obligations existing at the time of his death, but also those which have accrued
thereto since the opening of the succession.

Decedent’s interest
Decedent’s interest includes up to the extent of the decedent’s interest therein in the
properties at the time of his death. It shall include the following:
1. Dividends declared by a corporation before death of stockholder although paid
after death, if the decedent was living on the record date
2. Partnership profits even if paid after death of partner
3. Proceeds of life insurance policy payable to a revocable beneficiary
4. Right of usufruct if transferable to heirs

Transfer in contemplation of death

This means that it is the thought of death, as a controlling motive, which includes the
disposition of the property for the purpose of avoiding estate tax.

The main reason behind this provision is to reach ingenious schemes to evade the
estate tax liability, by the use of other forms of conveyances rather than by succession or
transfer mortis causa.

The following are examples of circumstances which may be taken into consideration
whether the transfer was made in contemplation of death.
a. Age and health of the decedent at the time of the gift, especially where he
was aware of a serious illness
b. Length of time between the gift and the date of death. A short interval
suggests the conclusion that the thought of death was in the decedent’s mind,
a long interval suggests the opposite.
c. Concurrent making of a will within a short time after the transfer

Thus, there is a transfer in contemplation of death when:

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a. The decedent transferred the possession or enjoyment of his property to

another, but this transfer was intended to take effect only upon his death
b. The decedent transferred title to the property but retained for his lifetime the
right to possess or enjoy the property or the income therefrom, or the rights to
designate whom shall possess or enjoy the same.

This does not apply when the sale is in good faith and for an adequate and full
consideration (Sec 84B, NIRC).

ILLUSTRATION When the doctor informed Concha that she is suffering from terminal
cancer, she decided to donate her house and lot worth P1,000,000 to
her friend, Migay.

1. Is this a transfer in contemplation of death?

- Yes, because the thought of death induced Concha to donate her
property. Considering that the transfer was made in contemplation
of death, it is subject to estate tax and not donor’s tax.

2. How about if the house and lot were sold at its actual value of P1,000,000 and after
the sale, Concha spent the entire amount before her death?
- There is no transfer in contemplation of death subject to estate tax
because there was a bona fide sale for an adequate and full
consideration in money or money’s worth.
- Moreover, the proceeds from the sale of property is not included as
part of the gross estate because the amount has been fully spent
before her death.

3. How about if after selling the house and lot, Concha dies without being able to spend
money, will the amount form part of her gross estate?
- Yes, it is included in the gross estate as part of decedent’s interest.

4. If shortly before she died, she lent the entire amount to her friend Boy Ngato, who
issued a promissory note. Will the receivable note form part of her gross estate?
- Yes, the value of the note receivable shall be included in her gross
estate (whether Boy Ngato is insolvent or not), but under
“decedent’s interest”.

Revocable transfers
This contemplates a situation where the decedent transfers the enjoyment of his
property to another, subject to his right to revoke the transfer at will, with or without notifying
the transferee, anytime before he dies.

Thus, the gross estate shall include the value of any property which the decedent has
at any time made a transfer by trust or otherwise:
a. With reserved power to alter, amend, revoke or terminate – where the
enjoyment thereof was subject at the date of his death to any change through
the exercise of a power (in whatever capacity exercisable) by the decedent
alone or by the decedent in conjunction with any other person (without regard

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to when or from what source the decedent acquired such power) to alter,
amend, revoke, or terminate
b. With such power relinquished – when any such power which would bring the
property in the taxable estate, is relinquished in contemplation of the
decedent’s death

It should be noted that revocable transfers shall not be included as part of gross
estate where the transfer is a bona fide sale for an adequate and full consideration in
money’s worth.

ILLUSTRATION Atong donated real property worth P500,000 to Bardagol during his
lifetime. An item in the deed, however, grants the donor the right to
revoke the donation at will.

a. Is the P500,000 subject to donor’s tax or to estate tax?

- The revocability of the donation at will of the donor made the
donation ambulatory. Furthermore, no right was vested in the donee
while the donor is alive. Therefore, the donation is subject to estate
tax.

b. Suppose the deed of donation contains a condition that Atong could reacquire only
the land upon the giving of a 30-day notice to Bardagol. Is the donation subject to
donor’s tax or to estate tax?
- The donation is still a mortis causa donation, subject to estate tax
because the requirement of notice has not changed the ambulatory
nature of the donation.

c. Suppose that Atong found out one day that he had a terminal cancer and had only
six months to live. He then relinquished his right to revoke under the donation for a
consideration of P1.00. Does this subject now the donation to donor’s tax instead of
estate tax?
- This is still a revocable transfer because the relinquishment of the
right to revoke was made in contemplation of death. Therefore, the
donation remains subject to estate tax.

Property passing under general power of appointment

A power of appointment is a right to designate by will or deed the person or persons
who are to receive certain property from the estate of a prior decedent.

A power of appointment may be either general or limited (special).

A special power of appointment is one which authorizes the donee or holder of the
power to appoint only among a restricted class or designated class persons other than
himself.

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If the donee can appoint any beneficiary including (a) himself, (b) his estate, (c) his
creditor, or (d) the creditors of his estate, then the power appointment is a general one.

However, if he can only appoint beneficiaries other than himself, his estate, his
creditor, or the creditors of his estate, then the power of appointment is a special one
because his power to appoint is limited to a certain class of persons only.
If the power of appointment is general, the decedent is practically the owner of the
property, and so the property is deemed part of his gross estate. But if the power is specific,
the decedent is only a trustee to the property, and so it should not be included in his estate.

ILLUSTRATION Alaskador died living a will whereby it was stipulated that his lot
situated in Cagayan de Oro City shall go to Buskador, and that should
the latter decide to transfer the property, he is free to give it to
anybody.

1. Is the power of appointment general or special?

- Since the power of appointment granted by Alaskador to Buskador
is not limited by any restriction, the power of appointment is general.
It is, therefore, subject to estate tax.

2. How about if the will expressly provides that Buskador can appoint only either of his
parents?
- The power of appointment is special because the right of Buskador
to appoint transferee to the property is restricted to certain person/s.

Transfer for insufficient consideration

If any of the above transfers, trusts, interests, rights or powers enumerated and
described (transfer in contemplation of death, revocable transfer, property passing under
general power of appointment) is made, created, exercised or relinquished for an adequate
consideration in money or money’s worth, there shall be included in the gross estate only the
excess of the fair market value, at the time of death, of the property otherwise to be included
on account of such transaction, over the value of the consideration received therefore by the
decedent.

If an inter vivos transfer is proven to be fictitious, the total value of the property at the
time of death shall be included in the gross estate.

ILLUSTRATION Mama Mathay sells her car worth P500,000 to Mommy Milli for
P200,000 in an arm’s length bona fide transaction.

1. Is the difference of P300,000 between the fair market and selling price includible in
the gross estate of Mama Mathay upon her death?
- No, because the transfer of the property does not fall under any of
the following: transfer in contemplation of death, revocable transfer,
and property passing under general power of appointment.
- Hence, the difference of P300,000 is subject to gift tax.

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2. Suppose it turns out later that Mama Mathay sold her car for insufficient
consideration because she knew she was dying. At the time of her death, the value
of the car has appreciated to P600,000. Is the difference subject to gift tax?
- No, because the transfer was made in contemplation of death.
Therefore, the difference between the fair market value at the time
of death and the selling price must form part of the gross estate.
The amount of gift tax paid, if any, can be claimed as a tax refund.

3. How about if it is proven that no consideration was given on the transfer of the
property?
- In that case, the entire value of the property at the time of death
(P600,000) and not the difference between the fair market value and
the selling price shall form part of the gross estate.

Proceeds of life insurance

This takes place when a person takes out an insurance policy in his own life and
appoints somebody as beneficiary.

The proceeds of life insurance covering the life of the insured are includible to the
gross estate, except when:
1. The beneficiary appointed in the policy is not the estate of the deceased, his executor
or administrator, and
2. The person designated as beneficiary is irrevocable.

It should be noted that there is a need to expressly stipulate the irrevocability of the
designation because in the absence of any stipulation, the law provides that the designation
is revocable.

The rule applies even if the proceeds never formed part of the estate because they
were paid by the insurer to the beneficiary of the estate.

The proceeds of life insurance payable to the person’s estate, on which the
premiums were paid by the conjugal partnership, constitute conjugal property, and the other
half pertains to the surviving spouse.

If the premiums were paid partly paraphernal and partly conjugal funds, the proceeds
are in like portion paraphernal in part and conjugal in part.

ILLUSTRATION Phil insured his life for P1,500,000. In the policy, he appointed Stan as
the beneficiary.

1. In case of death of Phil, will the proceeds from the insurance policy be subject
to estate tax?
- It depends.

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- If Stan is the executor or administrator of the estate of Phil, the

proceeds shall be included in the gross estate and, therefore,
subject to estate tax. The rule holds true whether the designation of
Stan as beneficiary is revocable or irrevocable.
- If Stan is neither the executor nor administrator, the proceeds of
insurance shall be exempt from estate tax provided that his
designation as beneficiary is irrevocable. Otherwise, it shall be
subject to estate tax.
- If the policy is silent, his designation is revocable. Hence the
proceeds shall be subject to estate tax.

2. Supposing the designation of Stan is revocable, will the proceeds form part of
the conjugal or of the exclusive property of Phil?
- If the premiums were paid out of the conjugal funds, then the
proceeds are conjugal. However, if the money used in paying the
premiums were taken from the exclusive properties of Phil, then the
proceeds shall be considered as exclusive properties.

The rule of taxability or non-taxability of life insurance proceeds is illustrated as

follows:
Beneficiary
(estate, executor
Case Policy or administrator) Taxable?
1 Revocable Yes Yes
2 Revocable No Yes
3 Irrevocable Yes Yes
4 Irrevocable No No
5 Silent No Yes

The law speaks of policies “taken out by the decedent upon his own life”. Thus
proceeds of a group insurance policy taken out by the company for its employees are not
subject to estate tax.

Moreover, proceeds of accident insurance are not also includible in the gross estate
because the tax code specifically mentions only life insurance poilicies.

Estate of an absentee
An absentee is a person who disappears from his domicile, his whereabouts being
unknown, and without leaving an agent to administer his property, or when the power
conferred to an agent has expired.

After an absence of seven years, it being unknown whether or not the absentee still
lives, he shall be presumed dead for all purposes, except for those of succession.

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The absentee shall not be presumed dead for the purpose of opening his succession
till after an absence of 10 years. If he disappeared after the age 75 years, an absence of five
years shall be sufficient in order that his succession may be opened.

The following shall be presumed dead for all purposes, including the division of the
estate among the heirs:
1. A person on board a vessel lost during a sea voyage, or an aeroplane which is
missing, who has not been heard of for four years since the loss of the vessel or
aeroplane.
2. A person in the armed forces who has not taken part in war, and has been missing
for four years
3. A person who has been in danger of death under the circumstances and his
existence has not been known for four years.

If the absentee appears, or without appearing his existence is proved, he shall

recover his property in the condition in which it may be found, and the price of any property
that may have been alienated or the property acquired therewith; but he cannot claim either
fruits or rents.

ILLUSTRATION On May 20, 2004, a ship named MV Princess of the Pacific sailed
from Matnog, Sorsogon. Lalo was seen to have boarded the ship but
since then nothing was ever heard of him. He was not also seen to
have alighted the ship when it reached the port in Allen, Samar.

1. For purposes of succession, when is Lalo presumed to be dead?

- The absentee is presumed dead for purposes of succession on May
20 2014 or 10 years after his absence, unless he disappeared at an
age of more than 75years in which case five years is sufficient in
order that his succession may be opened.

2. How about if the ship sunk somewhere in San Bernardino Strait and his body was
never recovered. For purposes of succession, when was Lalo presumed to have
died?
- On May 20, 2004, the exact date that the ship sunk.

Effect of absence upon the contingent rights of the absentee

Whoever claims a right pertaining to a person whose existence is not recognized
must prove that he was living at a time his existence was necessary in order to acquire said
right.

Upon the opening of succession to which an absentee is called, his share shall
accrue to his co-heirs, unless he has heirs, assigns, or a representative, they shall, as the
case may be, make an inventory of the property.

The provisions of the preceding paragraph are understood to be without prejudice to

the action of petition for inheritance or other rights which are vested in the absentee, his
representative or successors in interest.

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These rights shall not be extinguished save by lapse of time fixed for prescription. In
the record that is made in the Registry of the real estate which accrues to the co-heirs, the
circumstance of its being subject to the provisions of this article shall be stated.

Those who may have entered upon the inheritance shall appropriate the fruits
received in good faith so long as the absentee does not appear, or while his representatives
or successors in interest do not bring the proper actions.

ILLUSTRATION Antonino and Barcadero are the sons of Clayucay. When Calayucay
died, Antonino has been presumed dead under the law.
1. Who is entitled to the inheritance of Antonino from Calayucay?
- Barcadero unless Antonino has an heir, assignee or a
representative. In which case, the representative may register the
property in his own name, but Antonino may later on recover if he
turns out to be alive, unless he lost the right by prescription.

2. Who is entitled to the fruits of the inheritance?

- The right to the fruits is given to the person who was awarded the
property so long as the absentee has not reappeared, or while his
representatives or successors in interest do not bring the proper
actions. These right ceases when either the absentee reappears or
the proper action has been brought.

Reference:

Ampongan, O. E. G. (2020), Transfer, Business & Local Taxation (with Practice Set) 12/e

Bureau of Internal Revenue, Estate Tax,

https://www.bir.gov.ph/index.php/tax-information/estate-tax.html

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