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Identify the controlling doctrine in Philippine tax law that governs “escape from taxation” and apply it to the following scenario: A Philippine corporation, Sigma Industries, forms a wholly owned subsidiary, Sigma Spectrum Holdings, to hold a valuable telecommunications spectrum license. Sigma Industries sells all the shares of Sigma Spectrum Holdings to an unrelated buyer for PHP 120,000,000, while the fair market value of the license is PHP 520,000,000. Sigma Spectrum Holdings immediately sells the license to a third party for PHP 520,000,000. Throughout, Sigma Industries continues to control Sigma Spectrum Holdings and enjoys the economic benefits of the license. The arrangement was designed primarily to reduce Sigma’s tax on the sale and to minimize regulatory license taxes. (i) Should the BIR disregard the legal form and tax Sigma Industries as if it directly sold the spectrum license? (ii) If the arrangement is determined to be a sham designed to evade taxes, what civil and criminal liabilities may attach and what remedies are available to the government?