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Question
Metro Global, Inc. (MGI) is a resident domestic corporation with its principal office in Davao City. In the current taxable year, MGI earned: (i) 50 million pesos from Philippine operations; (ii) 20 million pesos as dividends from a foreign subsidiary in Japan; and (iii) 25 million pesos as royalties from a foreign licensing arrangement with a company in Singapore. (a)Identify the governing doctrine that determines whether MGI is subject to Philippine income tax on its foreign-sourced income and state the rule that applies to resident domestic corporations. (b)Apply the rule to the facts: are the 20 million foreign-sourced dividends and the 25 million foreign-sourced royalties included in MGI’s gross income for Philippine income tax? Explain briefly.