ASG Law

Tag: Retirement Fund

  • Retirement Fund Obligations: When is a Company Liable for Employee Separation Pay?

    The Supreme Court has affirmed that a company can be held liable for the unpaid separation pay of employees from its subsidiary if it obligated itself to fund the subsidiary’s retirement fund, or if it is considered an indirect employer. This ruling clarifies the extent of a parent company’s responsibility towards the employees of its subsidiaries, especially when operations cease and employees are terminated. It highlights the importance of clearly defining financial obligations in operational agreements and understanding potential liabilities under labor laws.

    The Light Rail’s Retirement Promise: Who Pays When the Ride Stops?

    The Light Rail Transit Authority (LRTA), a government-owned corporation, had a ten-year operations and management (O&M) agreement with Meralco Transit Organization, Inc. (MTOI). LRTA later acquired MTOI, renaming it Metro Transit Organization, Inc. (METRO), but maintained it as a separate entity. When the O&M agreement ended, METRO ceased operations, leading to the termination of its employees, including Romulo Mendoza, Francisco Mercado, Roberto Reyes, Edgardo Cristobal, Jr., and Rodolfo Roman. These employees received only half of their separation pay and sought the remainder from LRTA, arguing that LRTA was obligated to cover the full amount. This case examines whether LRTA is responsible for the remaining separation pay of METRO’s employees, despite the absence of a direct employer-employee relationship.

    LRTA argued that it had no employer-employee relationship with the respondents and that the National Labor Relations Commission (NLRC) had no jurisdiction over the case. They cited the case of LRTA v. Venus, Jr., stating that as a government-owned and controlled corporation, disputes should be under the Civil Service Commission’s jurisdiction. However, the Supreme Court disagreed, emphasizing that the issue was not about the respondents’ employment with LRTA, but about LRTA’s liability for the money claims. The Court referenced Phil. National Bank v. Pabalan, noting that by engaging in business through a corporation, the government subjects itself to the rules governing private corporations.

    The Supreme Court found LRTA liable for the unpaid separation pay based on two primary reasons. First, LRTA had obligated itself to fund METRO’s retirement fund, which included provisions for separation benefits. The O&M agreement between LRTA and METRO stipulated that LRTA would reimburse METRO for operating expenses. A letter from the Acting Chairman of the METRO Board of Directors, Wilfredo Trinidad, confirmed that funding for the retirement fund had always been considered an operating expense. Furthermore, LRTA Board Resolution No. 00-44, issued on July 28, 2000, demonstrated LRTA’s intent to update the Metro, Inc., Employee Retirement Fund to ensure it fully covered all retirement benefits payable to METRO’s employees.

    Secondly, the Court determined that LRTA was solidarily liable as an indirect employer for the respondents’ separation pay. Under Article 107 of the Labor Code, an indirect employer is any entity that contracts with an independent contractor for the performance of work. Article 109 of the Labor Code mandates that every employer or indirect employer shall be responsible with its contractor or subcontractor for any violation of the Labor Code. Department Order No. 18-02, s. 2002, implementing Articles 106 to 109 of the Labor Code, provides that the principal shall be solidarily liable if the contract is preterminated for reasons not attributable to the contractor or subcontractor.

    In this case, the non-renewal of the O&M agreement was solely at the behest of LRTA, making them responsible for the adverse effects on METRO’s employees. While it was a non-renewal rather than a pretermination, the effect on the workers—the involuntary loss of their employment—was the same. The court reinforced its stance by quoting relevant articles from the Labor Code, illustrating the extent of an indirect employer’s liability. Specifically, Article 109 states that:

    “x x x every employer or indirect employer shall be held responsible with his contractor or subcontractor for any violation of any provisions of this Code. For purposes of determining the extent of their civil liability under this Chapter, they shall be considered as direct employers.”

    The decision also addressed the issue of prescription, with the LRTA arguing that the respondents’ claim had already prescribed. The Court cited De Guzman v. Court of Appeals, affirming the applicability of Article 1155 of the Civil Code to an employee’s claim for separation pay. The Court agreed with the NLRC’s conclusion that the prescriptive period for respondents’ claim was interrupted by their letters to LRTA demanding payment of the balance of their separation pay. Article 1155 of the Civil Code states:

    “The prescription of actions is interrupted when they are filed before the court, when there is a written extrajudicial demand by the creditors, and when there is a written acknowledgment of the debt by the debtor.”

    In conclusion, the Supreme Court dismissed LRTA’s petition, affirming the decision of the Court of Appeals and reinstating the Labor Arbiter’s decision. The Court emphasized that LRTA could not evade its responsibility to the employees of its subsidiary, METRO, due to its contractual obligations and its role as an indirect employer. This ruling serves as a reminder to companies about the importance of understanding their responsibilities and potential liabilities in business relationships, particularly in the context of labor law.

    FAQs

    What was the key issue in this case? The key issue was whether LRTA, as the parent company of METRO, was liable for the unpaid separation pay of METRO’s employees after the O&M agreement ended and METRO ceased operations. This involved determining if LRTA had a contractual obligation or acted as an indirect employer.
    Did the Supreme Court find LRTA liable? Yes, the Supreme Court affirmed the lower courts’ decisions, holding LRTA liable for the remaining 50% of the employees’ separation pay. The court based this decision on LRTA’s obligation to fund METRO’s retirement fund and its status as an indirect employer.
    What is an indirect employer under the Labor Code? An indirect employer is any entity that contracts with an independent contractor for the performance of work, task, job, or project. The Labor Code holds indirect employers solidarily liable with the contractor for violations of the code.
    What was the significance of LRTA Board Resolution No. 00-44? LRTA Board Resolution No. 00-44, issued on July 28, 2000, authorized the updating of the Metro, Inc., Employee Retirement Fund. This resolution demonstrated LRTA’s intent to ensure the fund fully covered all retirement benefits payable to METRO’s employees, solidifying LRTA’s obligation.
    How did the O&M agreement affect LRTA’s liability? The O&M agreement between LRTA and METRO stipulated that LRTA would reimburse METRO for operating expenses. The courts interpreted this to include funding for the retirement fund, thus creating a contractual obligation for LRTA to cover the separation pay.
    What is the effect of the government engaging in business through a corporation? When the government engages in business through a corporation, it subjects itself to the rules governing private corporations. This means that government-owned corporations can be held liable under the Labor Code, like any private entity.
    What is the role of Department Order No. 18-02, s. 2002? Department Order No. 18-02, s. 2002, provides the rules implementing Articles 106 to 109 of the Labor Code. It clarifies the solidary liability of the principal in cases where the contract is preterminated for reasons not attributable to the contractor or subcontractor.
    How did the court address the prescription issue? The Court affirmed that the prescriptive period for the respondents’ claim was interrupted by their written demands to LRTA for payment of the remaining separation pay. This interruption is based on Article 1155 of the Civil Code.

    This case underscores the importance of clearly defining contractual obligations and understanding the potential liabilities associated with subsidiary relationships and operational agreements. Companies must ensure that they are aware of their responsibilities under labor laws, both as direct and indirect employers, to avoid similar disputes.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: LIGHT RAIL TRANSIT AUTHORITY vs. ROMULO S. MENDOZA, ET AL., G.R. No. 202322, August 19, 2015

  • Protecting Employee Retirement Funds: Invalidating Reversion of Assets to Cover Corporate Debt

    The Supreme Court ruled that a company’s retirement fund assets cannot be used to settle the company’s debts until all employee benefits are fully paid. This decision safeguards the financial security of employees by ensuring that retirement funds are prioritized for their intended purpose: providing for employees’ retirement and separation benefits. The ruling reinforces the fiduciary duty of trustees to protect these funds and prevents companies from inappropriately diverting them for their own financial gain, which can lead to legal battles to protect employee rights.

    Safeguarding Retirement: When Corporate Debt Clashes with Employee Benefits

    The case of Metropolitan Bank & Trust Company vs. The Board of Trustees of Riverside Mills Corporation Provident and Retirement Fund revolves around the contentious issue of whether a company can utilize its employees’ retirement fund to settle its outstanding debts with a bank. Riverside Mills Corporation (RMC) established a Provident and Retirement Plan (the Plan) for its employees, funded by contributions from both the company and its employees. Metropolitan Bank & Trust Company (MBTC), as successor to Philippine Banking Corporation (Philbank), sought to apply the assets of the Riverside Mills Corporation Provident and Retirement Fund (RMCPRF) to cover RMC’s unpaid obligations. This move was challenged by the employees, leading to a legal battle that ultimately reached the Supreme Court.

    At the heart of the dispute was the interpretation of the trust agreement governing the RMCPRF and the rights of the employee-beneficiaries. The Plan explicitly stated that the assets of the Fund should be used exclusively for the benefit of its members and their beneficiaries. It further stipulated that “[i]n no event shall any part of the assets of the Fund revert to [RMC] before all liabilities of the Plan have been satisfied.” This provision became a critical point of contention, as MBTC argued that RMC’s closure in 1984 effectively rendered the RMCPRF Board of Trustees defunct and allowed for the reversion of the Fund to RMC’s general assets.

    However, the Supreme Court firmly rejected this argument, emphasizing the fiduciary nature of the trust relationship and the paramount importance of protecting the interests of the employee-beneficiaries. The Court underscored that employees’ trusts or benefit plans are specifically designed to provide economic security during retirement, death, sickness, or disability. As such, these funds are independent and additional sources of protection established exclusively for the benefit of the working group.

    The Court highlighted the distinction between dismissals for just cause and authorized cause under the Labor Code, as amended. Just causes, outlined in Article 282, involve employee misconduct, fraud, or neglect of duties, while authorized causes, under Articles 283 and 284, arise from employer’s prerogative or employee illness. The Court noted that the Plan stipulates that employees separated for cause, referring to just causes under Article 282, would not be entitled to withdraw contributions. Since RMC’s closure constituted an authorized cause for termination, all employees, including those laid off, were entitled to receive the balance of their accounts, including a portion of the company’s contributions and income earned.

    Furthermore, the Supreme Court scrutinized the Investment Management Agreement between the RMCPRF Board of Trustees and Philbank (now MBTC). Paragraph 6 limited MBTC’s function to liquidation and return of the Fund to the Board upon termination of the Agreement. Paragraph 14 explicitly stated that the Investment Manager’s duty was to transfer all assets to its successor or successors, less authorized charges. The Court stated that petitioner had no power to effect reversion of the Fund to RMC, highlighting that MBTC, as trustee, was obligated to act in the best interests of the beneficiaries.

    The Court also addressed MBTC’s claim that it had made diligent efforts to locate claims against the Fund. It criticized MBTC’s passive approach, noting that the readily identifiable beneficiaries of the Fund were the regular employees of RMC. Securing a list of these employees from the Board of Trustees or RMC itself would have been a straightforward process. The Court observed that MBTC only notified the Board of Trustees after deciding to apply the Fund to RMC’s liabilities, demonstrating a lack of good faith and disregard for the employees’ rights.

    Regarding the authority of the Board of Trustees, the Court cited Section 122 of the Corporation Code, which allows a dissolved corporation to continue as a body corporate for three years to settle its affairs. Similarly, the RMCPRF Board of Trustees retained authority to settle the Fund’s affairs. The Board’s resolution authorizing the release of the Fund to its beneficiaries was deemed part of the liquidation process and within the Board’s power to enact.

    The Supreme Court affirmed the award of attorney’s fees to the respondents, citing Article 2208(2) of the Civil Code. This provision allows for such awards when the defendant’s actions compel the plaintiff to litigate to protect their interests. The Court found that MBTC’s unauthorized application of the Fund to RMC’s obligations, without proper inquiry into unpaid claims, necessitated the employees’ legal action.

    FAQs

    What was the key issue in this case? The central issue was whether Metropolitan Bank & Trust Company (MBTC) could legally use the assets of the Riverside Mills Corporation Provident and Retirement Fund (RMCPRF) to cover the outstanding debts of Riverside Mills Corporation (RMC). The Supreme Court ultimately decided that the assets could not be used for this purpose.
    What did the Riverside Mills Corporation Provident and Retirement Plan (the Plan) state about the fund’s assets? The Plan stipulated that the assets of the fund should be used exclusively for the benefit of its members and their beneficiaries. Furthermore, the Plan specifically stated that no part of the assets could revert to RMC until all liabilities of the Plan had been satisfied.
    Why did the bank think it could use the retirement fund to pay off the company’s debt? The bank argued that because Riverside Mills Corporation (RMC) had ceased business operations in 1984, the retirement fund had technically reverted to RMC’s assets. Therefore, they thought they were justified in using the fund to pay off RMC’s debts to the bank.
    What was the Supreme Court’s reasoning for protecting the retirement fund? The Supreme Court emphasized the fiduciary nature of the trust relationship, underscoring the importance of protecting the interests of the employee-beneficiaries. Retirement funds are designed to provide economic security during retirement, and thus should be protected.
    What is the difference between dismissal for ‘just cause’ and ‘authorized cause’ in relation to this case? ‘Just cause’ involves employee misconduct, while ‘authorized cause’ arises from employer’s prerogative or employee illness. The distinction is crucial because, in this case, RMC’s closure was an authorized cause, entitling all employees to benefits.
    What was the bank’s responsibility as the trustee of the retirement fund? The bank’s responsibility was limited to the liquidation and return of the Fund to the Board of Trustees. It had no power to unilaterally revert the Fund to RMC, as its duty was to act in the best interests of the beneficiaries.
    Why did the Supreme Court uphold the award of attorney’s fees to the employees? The Court upheld the award because the bank applied the Fund to the company’s obligation without authority and without inquiring about unpaid claims from the Board of Trustees. This unauthorized action compelled the employees to seek judicial relief to protect their rights.
    What does Section 122 of the Corporation Code have to do with this case? Section 122 of the Corporation Code allows a dissolved corporation to continue as a body corporate for three years to settle its affairs. This section allowed the RMCPRF Board of Trustees to retain authority to act on behalf of its members to close the affairs of the Fund.

    This Supreme Court decision serves as a strong reminder of the legal protections afforded to employee retirement funds. It clarifies the responsibilities of trustees and employers, reinforcing the principle that these funds are to be used exclusively for the benefit of the employees. It reinforces the fiduciary duty of trustees to protect these funds and prevents companies from inappropriately diverting them for their own financial gain.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Metropolitan Bank & Trust Company, Inc. v. The Board of Trustees of Riverside Mills Corporation Provident and Retirement Fund, G.R. No. 176959, September 08, 2010

  • Tax Refund Denied: Why Procedure and Evidence are Key in Philippine Tax Cases

    Missed Tax Refunds: The High Cost of Procedural Errors and Insufficient Evidence

    In tax law, even a valid claim can be lost due to procedural missteps or lack of proper documentation. This case underscores that meticulous adherence to rules and robust evidence are as crucial as the merits of the claim itself, especially when seeking tax refunds from the Bureau of Internal Revenue (BIR). Learn why Far East Bank’s bid for a retirement fund tax refund failed despite the funds’ tax-exempt status.

    G.R. NO. 138919, May 02, 2006

    INTRODUCTION

    Imagine your company diligently sets up retirement funds for employees, understanding these funds are legally tax-exempt. Years later, you discover taxes were mistakenly withheld from these funds’ earnings. Seeking a refund seems straightforward, right? Not always. Far East Bank and Trust Company, as trustee for numerous retirement funds, learned this the hard way. They sought to recover taxes wrongfully paid on retirement fund income, a claim rooted in legal exemption. However, their journey through the Philippine legal system reveals a stark reality: even valid claims can falter on the rocky ground of procedural errors and insufficient proof. The central legal question became less about the tax exemption itself and more about whether Far East Bank properly navigated the legal maze to reclaim those taxes.

    LEGAL CONTEXT: Tax Exemptions for Retirement Funds and the Two-Year Refund Deadline

    Philippine law, recognizing the importance of employee welfare, provides tax exemptions for income generated by legitimate retirement funds. Republic Act No. 4917, enacted to promote private benefit plans for employees, explicitly states that “retirement benefits received by officials and employees of private firms…in accordance with a reasonable private benefit plan maintained by the employer shall be exempt from all taxes.” This exemption was carried over into subsequent tax laws, including Republic Act No. 8424, the Tax Reform Act of 1997, and is currently found in Section 60(B) of the National Internal Revenue Code (NIRC). This legal provision essentially shields the earnings of qualified employees’ trusts from income tax, fostering a secure financial future for retirees.

    However, even with a clear legal basis for exemption, claiming a tax refund in the Philippines is governed by strict rules. Section 230 of the NIRC (in effect during the taxable year in question) is unequivocal about the prescriptive period for claiming refunds of erroneously or illegally collected taxes. It states: “In any case, no such suit or proceeding shall be begun after the expiration of two years from the date of payment of the tax or penalty…” This two-year deadline is a cornerstone of tax administration, designed to ensure timely resolution of tax matters and prevent indefinite claims against government revenue. Failure to file a claim within this period is generally fatal to the refund claim, regardless of the underlying merits.

    In essence, while the law generously exempts retirement fund income from taxation, it simultaneously imposes stringent procedural requirements for reclaiming taxes mistakenly paid – a balance between promoting employee benefits and maintaining fiscal order.

    CASE BREAKDOWN: A Procedural Labyrinth and Evidentiary Shortfall

    Far East Bank, acting as trustee for numerous employee retirement funds, invested these funds and earned interest income in 1993. Believing these earnings to be tax-exempt under RA 4917, they filed claims for refund of withheld taxes totaling over P6 million. Initially, they filed written claims with the Bureau of Internal Revenue (BIR), citing a Supreme Court precedent affirming the tax-exempt status of employees’ trusts.

    Facing BIR denial and with the two-year prescriptive period looming, Far East Bank had already initiated another case in the Court of Tax Appeals (CTA) concerning a similar issue from a prior year. Hoping to consolidate matters, they attempted to amend this existing CTA case by filing a “Supplemental Petition” to include the 1993 refund claim. However, the CTA rejected this move, advising them to file a separate petition for the 1993 claims due to the advanced stage of the original case. The CTA did, however, explicitly acknowledge the option to file a separate petition.

    Following the CTA’s advice, Far East Bank filed a new petition for review (CTA Case No. 5292) specifically for the 1993 refunds. The Commissioner of Internal Revenue (CIR) raised prescription as a defense, pointing out that the judicial claim was filed beyond the two-year period from the dates of tax payments for the first three quarters of 1993.

    The CTA sided with the CIR on prescription for the majority of the claim. The court stated: “the claims for refund had already prescribed insofar as they covered the first, second and third quarters of 1993, as well as from the period of 1 October to 8 October 1993. The CTA so ruled considering that the petition before it was filed only on 9 October 1995, and thus, only those claims that arose after 9 October 1993 could be considered…” Effectively, only a small portion of the fourth quarter claims remained potentially viable.

    However, even for this remaining period, the CTA denied the refund based on insufficient evidence. The court found that Far East Bank failed to adequately prove that the income was indeed derived from the retirement funds’ investments. The CTA elaborated: “…the evidence of the petitioner for the remaining portion of the claim for the fourth quarter of 1993 is insufficient to establish the fact that the money or assets of the funds were indeed used or placed in money market placements, bank deposits, other deposit substitute instruments and government securities, more particularly treasury bills.” Crucially, the CTA noted the absence of key transactional documents like confirmation receipts and purchase orders, which are considered “best evidence.”

    Far East Bank appealed to the Court of Appeals (CA), but their petition was outrightly dismissed for procedural lapses – specifically, failing to attach crucial documents like the Supplemental Petition and CTA Resolutions to their CA petition. Even when these documents were belatedly submitted, the CA upheld its dismissal, noting no reversible error in the CTA decision.

    Finally, the Supreme Court (SC) affirmed the lower courts. The SC emphasized the importance of procedural compliance in appeals, stating that attaching certified true copies of relevant records is “not a mere technicality that can be overlooked with ease, but an essential requisite for the determination of prima facie basis for giving due course to the petition.” Even overlooking the procedural issues, the SC agreed with the CTA’s assessment of insufficient evidence. The Court concluded that while retirement funds are indeed tax-exempt, Far East Bank failed to conclusively prove that the income in question originated from these exempt funds and to quantify the refundable amount with sufficient certainty.

    PRACTICAL IMPLICATIONS: Lessons for Taxpayers and Trustees

    This case serves as a stark reminder of several critical points for taxpayers, especially those handling tax-exempt funds or seeking refunds:

    • Strict Adherence to Deadlines: The two-year prescriptive period for tax refund claims is ironclad. Monitor payment dates meticulously and file claims well within the deadline. Do not assume supplemental filings in other cases will automatically toll the prescriptive period for new claims.
    • Meticulous Documentation is Non-Negotiable: For tax refunds, especially concerning exemptions, robust documentation is paramount. Retain and organize all transaction records, confirmation receipts, purchase orders, and bank statements that directly link income to the exempt source. General certifications without detailed breakdowns are often insufficient.
    • Procedural Rules Matter as Much as Substance: Navigating the court system requires strict adherence to procedural rules. Familiarize yourself with the Rules of Court, especially Rule 43 for appeals from the CTA. Ensure all required documents are attached to petitions and motions, in certified true copy form when necessary.
    • Seek Expert Legal and Tax Advice Early: Tax law is complex. Engage competent tax advisors and legal counsel from the outset, especially when dealing with exemptions and refunds. Professional guidance can prevent costly procedural errors and ensure proper evidence presentation.
    • Burden of Proof on Taxpayer: Remember, the burden of proving a tax refund claim rests squarely on the taxpayer. Do not assume the BIR or courts will automatically grant a refund, even if the legal basis seems clear. Proactive and thorough evidence gathering is essential.

    Key Lessons from Far East Bank vs. CIR:

    • Timeliness is critical: File refund claims within the two-year prescriptive period.
    • Evidence is king: Substantiate your claims with detailed transactional documents.
    • Procedure is paramount: Comply strictly with court rules and deadlines.
    • Expert help is invaluable: Seek professional tax and legal advice.

    FREQUENTLY ASKED QUESTIONS (FAQs)

    Q: What is the prescriptive period for filing a tax refund claim in the Philippines?

    A: Under Section 229 of the National Internal Revenue Code, as amended, a taxpayer has two (2) years from the date of payment of the tax to file a claim for refund or credit of erroneously or illegally assessed or collected taxes.

    Q: What kind of evidence is needed to support a tax refund claim for retirement funds?

    A: You need to provide documentary evidence that clearly links the income to the tax-exempt retirement fund and substantiates the amount of tax withheld. This includes trust agreements, investment records, confirmation receipts, purchase orders, bank statements showing fund transactions, and detailed withholding tax certificates specifically identifying income from the retirement funds.

    Q: What happens if I file my tax refund claim late?

    A: If you file your claim beyond the two-year prescriptive period, your claim will likely be denied due to prescription, regardless of the merits of your claim. The BIR and courts strictly enforce this deadline.

    Q: Can I amend a pending court case to include a new tax refund claim?

    A: While you can attempt to file a supplemental petition to include new claims in an existing case, the court has discretion to deny it, especially if it would unduly delay proceedings or change the cause of action significantly. It’s generally safer to file a separate petition for new claims, particularly when prescription is a concern.

    Q: What are the common procedural errors to avoid when appealing a tax case?

    A: Common errors include failing to attach required documents (like lower court decisions and relevant records) to your petition, not filing within the prescribed appeal period, and not properly serving the petition on the concerned parties. Always double-check the Rules of Court for specific requirements.

    Q: Are all employee retirement funds tax-exempt in the Philippines?

    A: Generally, yes, if they qualify as reasonable private benefit plans under Philippine law (RA 4917 and subsequent tax codes). The income earned by these funds is typically exempt from income tax. However, specific requirements and BIR rulings may apply to determine qualification.

    Q: What is the Court of Tax Appeals (CTA)?

    A: The Court of Tax Appeals is a special court in the Philippines that exclusively handles tax-related cases. It has jurisdiction over decisions of the Commissioner of Internal Revenue and the Commissioner of Customs. Appeals from the CTA used to go to the Court of Appeals, but now go directly to the Supreme Court.

    Q: Why was Far East Bank’s claim ultimately denied despite the tax exemption for retirement funds?

    A: The claim was denied due to a combination of factors: partial prescription because the judicial claim was filed late for some tax payments, procedural errors in their appeal to the Court of Appeals, and most importantly, insufficient evidence to prove the income was from tax-exempt retirement funds and to accurately quantify the refundable amount.

    ASG Law specializes in Tax Law and Litigation. Contact us or email hello@asglawpartners.com to schedule a consultation.