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If you are a tax professional, you know your client is in a pickle if a tax provision disallows a deduction and another provision subjects the corresponding income to U.S. tax.
Raluca Enache, Christiana Loizou and Paulina Laine of KPMG ask whether there is any order in the chaos of the efforts to create a more effective system of withholding tax.
Last year, the Bureau of Internal Revenue issued Revenue Memorandum Order 14-2021, streamlining the procedures for the availment of tax treaty benefits. This RMO updated the guidelines and procedures and supposedly reformat the manner of confirming the entitlement to treaty benefits. With these objectives, the new RMO gave the income…