RC NRC RA NRA ESTATE TRUST arrangement where one person (grantor/ trustor ) Ph citizen who convinced commissioner his physical EB NEB transfers/donates property to another person Filipino citizen residing in PH Lives in Ph but no definite intention as to his stay presence abroad with definite intention to reside there (beneficiary ) which will be held under the management more than 180 days during the yr BUT not more than properties, rights and obligations (not extinguished by of a third party (trustee/fiduciary ) not more than 180 days during the yr 1 yr death) left behind of a deceased person The TRUST is the property Ph citizen who leaves ph during taxable yr to reside abroad (either as immigrant or for an employment on if under judicial settlement : treated as individual if designation of trust is irrevocable by grantor : like permanent basis) Who comes to PH for definite purpose with its nature taxpayers (estate is taxable on the income of judicial settlement; trust becomes the taxp (as if indiv requiring an extended stay making PH his temporary has definite purpose which can be accomplished properties left by the decendent) taxp). The income held in trust is taxable to the trust home, although it may be his intention to return immediately (eg contract) abroad at all times if under extrajudicial settlement : EXEMPT. Estate if designation of trust is revocable: not income is taxable to the heir. Heir is the taxp not the taxable entities, trust not considered indiv taxp. The Ph citizen working and derives income from abroad estate income of trust is taxable to grantor not to trust and whose employment requires him to be physically present abroad most of the time during the taxable yr if silent: REVOCABLE stayed for more than 1 year as of the end of the taxable yr Citizen previously considered as NRC who arrives in Ph anytime during the taxable yr to reside permanently in PH. He is NRC in the taxable yr when he arrived only to his income derived abroad