Nature and extent of tax lien.
Section 315
SEC. 315. Nature and extent of tax lien. — Every internal-revenue tax on property or on any business or occupation, and every tax on resources and receipts, and any increment to any of them incident to delinquency, shall constitute a lien superior to all other charges or liens not only on the property itself upon which such tax may be imposed but also upon the property used in any costs that may accrue in addition thereto upon all property and rights to property belonging to the taxpayer business or occupation upon which the tax is imposed and upon all property rights therein. The estate tax shall be a lien for five years upon the gross estate of the decedent from the date the tax becomes legally due. The lien of the tax on inheritances, legacies, and other acquisitions mortis causa shall be superior to all other liens, mortgages, encumbrances, or real right created thereon subsequent to the death of the predecessor, and shall be enforceable against the property inherited whether in the possession of the delinquent owner or purchaser, but this lien will be extinguished at the end of five years from the date when the tax becomes legally due. The tax on gifts shall be a lien upon all gifts made during the calendar year, for five years from the time the tax becomes legally due. If the tax is not paid when due the taxpayer (donor or donee) shall be personally liable for such tax to the extent of the value of such gift. Any part of the property comprised in the gift sold by the donee to a bona fide purchaser for an adequate and full consideration in money or money's worth shall be divested of the lien herein imposed and the lien, to the extent of the value of such gift, shall attach to all the property of the taxpayer (donor or donee), including after-acquired property, except any part sold to a bona fide purchaser for an adequate and full consideration in money or money's worth. If any person, corporation, partnership, joint-account (cuenta en participacion), association, or insurance company liable to pay the income tax, neglects or refuses to pay the same after demand, the amount shall be a lien in favor of the Government of the Philippines from the time when the assessment was made by the Collector of Internal Revenue until paid, with interest, penalties, and Provided, That this lien shall not be valid against any mortgagee, purchaser, or judgment creditor until notice of such lien shall be filed by the Collector in the office of the register of deeds of the province or city where the property of the taxpayer is situated or located.