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Question
(a) TranTech Philippines, Inc. is a corporation organized and existing under Philippine law. It is 60% foreign-owned and 40% Filipino-owned. The management and control are located in Manila, and all strategic decisions are made there. It derives all of its income from Philippine sources. For income tax purposes, classify TranTech Philippines, Inc. as domestic or foreign, and explain the basis for your classification.
(b) Luma Freight Corp., a foreign corporation organized under the laws of Singapore, has established a permanent establishment in the Philippines through a branch in Cebu. It engages in business in the Philippines and earns Philippine-sourced income. For income tax purposes, classify Luma Freight Corp. as RFC or NRFC, and explain the basis.