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“But the President came out yesterday and said, ‘Yes, there was verbal agreement.’ Now the problem is, that binds us,” Carpio said, in an interview.Carpio, who has been a strong advocate of Philippines’ sovereign interest in the South China Sea, particularly the WPS, said that the only way to stop the President’s verbal agreement is for the Senate to adopt a resolution disapproving it. And so it needs ratification by the Senate,” Carpio said, adding that a Senate resolution on the need for its concurrence would also give Duterte a way to save face.Earlier, the President said he might use his fourth State of the Nation Address on July 22 to “educate” his critics on his verbal fishing deal with Chinese President Xi Jinping.But Carpio advised the President not to tackle in his SONA the matter of the fishing deal with China because it will make the verbal agreement binding to the Philippine government.“The only way we can stop this is for the Senate as soon as they convene to pass a resolution repudiating it. “Or the Senate can, if they want to be diplomatic about it, say that a verbal agreement cannot take effect until we ratify it. Carpio said the verbal fishing deal with China which supposedly also allows Filipino fishers to fish in China-controlled areas in the South China Sea was an international agreement on a substantive issue and needed Senate concurrence. “I don’t think the Senate will ratify,” Carpio said.
For audits of multiple years, separate LOAs need to be issued.
These documents (NIC, FLD, PAN, and FAN) need to be received by an authorized representative of the taxpayer. The Court of Tax Appeals (CTA) ruled that such receipt does not count.
As such, the CTA ruled that since the documents were not received by the proper authorized representatives, the assessments issued for that audit are deemed void as well.
The LOA needs to be served to the taxpayer within 30 calendar days of its issuance, otherwise it is voided and will need to be revalidated.
Once the LOA has been issued, the actual audit can begin.
The balancing factor, according to the Supreme Court, is ensuring that all audits are properly authorized. Letter notices cannot replace LOAs, and as such do not authorize further examinations or assessments.