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Vivian is an American citizen, a resident of the Philippines for almost 9 months, He left 2 (two) properties registered under his name, one is

Vivian is an American citizen, a resident of the Philippines for almost 9 months, He left 2 (two) properties registered under his name, one is located in Paris and the other is located in Boracay. His daughter Susana Collins went to BIR and asked for the assessment of the estate tax. However, in the computation, BIR included these two properties, is BIR correct? Answer with legal basis under the TRAIN Law of the Philippines.

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