Under the Philippine's National Internal Revenue Code of
1997 (the "Tax Code"), the term "corporation"
includes partnerships, no matter how created or organized,
joint-stock companies, joint accounts (cuentas en participation),
associations, or insurance companies, but excluding general
professional partnerships and a joint venture or consortium formed
for the purpose of undertaking construction projects or engaging in
petroleum, coal, geothermal and other energy operations pursuant t
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