Strategic Counsel.
Practical Execution.
Decisive Outcomes.

Advised a client on the acquisition, legal validation, and full regulatory registration of a commercial vessel with a highly complex history—including prior government seizure, public auction, and the complete absence of ownership and technical documentation at the time of purchase.

The vessel had been seized in connection with smuggling enforcement and later sold through public bidding. Our client acquired it from the auction winner, but inherited significant challenges: no Certificate of Ownership (CO), no Certificate of Philippine Registry (CPR), no approved vessel plans, and multiple prior ownership transfers requiring reconstruction of title.

We delivered end-to-end legal and regulatory support, working closely with the Maritime Industry Authority (MARINA) to establish a compliant pathway to registration. Our work included:

• Comprehensive Due Diligence — Reconstructed the vessel's history, validating the auction process, prior ownership chain, and regulatory risks despite the absence of formal records.
• Regulatory Strategy & Government Engagement — Coordinated closely with MARINA to determine a legally sound registration approach, including exploratory ("no-name") inquiries to navigate regulatory constraints.
• Reconstruction of Technical Documentation — Led the preparation of all required vessel plans and technical documents—from structural layouts to safety and stability systems—necessary for regulatory approval.
• Multi-Stage Registration & Ownership Transfers — Successfully managed two separate ownership transfers and registration processes, ensuring continuity of title and full compliance at each stage.
• Securing Registration & Operational Clearance — Obtained the issuance of Certificates of Ownership and Philippine Registry, and completed final registration under the client's name.

Transformed a vessel with no documentation and significant regulatory uncertainty into a fully compliant, legally registered asset—restoring its operational viability and enabling lawful commercial use.

Represented a multinational fast-moving consumer goods (FMCG) company—one of the largest globally by revenue—in a high-stakes tax audit conducted by the Bureau of Internal Revenue's Large Taxpayers Service (BIR-LTS), involving a multi-billion peso deficiency tax assessment.

At the outset, the client faced a proposed deficiency tax assessment exceeding ₱14 billion, arising from complex income tax and value-added tax (VAT) issues. The audit involved aggressive positions and heightened scrutiny typical of LTS examinations, creating significant legal, financial, and reputational exposure.

We provided end-to-end tax controversy support, covering audit defense, legal strategy, and settlement negotiations:

• Strategic Case Assessment — Conducted a comprehensive legal and tax analysis of the BIR-LTS findings, identifying key weaknesses in the assessment and developing a defense grounded in law, jurisprudence, and regulatory issuances.
• Evidence-Driven Defense — Built a fully substantiated position based on accounting records, tax filings, and supporting documentation—ensuring all arguments were fact-based and defensible.
• Audit Management & Representation — Led all stages of the audit process, including conferences, submissions, and negotiations, while maintaining a consistent and credible position before regulators.
• Negotiation & Risk Management — Navigated settlement discussions strategically, balancing legal strength with commercial considerations to achieve an optimal resolution.

Secured a 99.67% reduction in the proposed deficiency tax assessment—equivalent to approximately ₱14 billion—resulting in a highly favorable outcome for the client.

Over the past year, we have successfully handled multiple tax controversy engagements spanning 10 taxable years, including a fraud audit covering four years.

• Total Initial Assessments: ~₱306.2 million
• Total Settlements: ~₱10.0 million
• Overall Reduction Achieved: ~96.7%

These engagements covered a wide range of industries and audit types, reflecting our consistent ability to materially reduce tax exposure through a disciplined, evidence-based, and strategically executed approach.

Advised a licensed online lending and fintech company in navigating complex regulatory proceedings before the Securities and Exchange Commission (SEC), including enforcement actions, compliance walkthroughs, and field audits.

The client faced heightened regulatory scrutiny, including a Formal Charge from the SEC's Financing and Lending Companies Division (FLCD) and an on-site audit by the Enforcement and Investor Protection Department (EIPD)—exposing the business to significant legal, operational, and reputational risk.

We provided end-to-end regulatory and compliance support, combining legal defense, proactive regulator engagement, and operational remediation:

Successfully secured the resolution of the SEC Formal Charge and closure of audit findings, while significantly strengthening the client's compliance framework—enabling continued operations under improved regulatory standing.