BIR REVENUE MEMORANDUM CIRCULAR NO. 47-97

: No, delivery (actual or constructive) of the certificates of stock to the stockholders is not essential for the DST to attach.
: Yes, under Philippine Corporation Law, a subscriber or purchaser of stock becomes a stockholder as soon as the subscription is accepted by the corporation, even without receiving a certificate.
: The stockholder has all rights and liabilities of stock ownership, including voting rights, dividends, and responsibilities, irrespective of holding the physical certificate.
: They are enjoined to give the circular as wide publicity as possible to ensure compliance with the documentary stamp tax requirements.
: It is a tax on the privilege of issuing shares of stock, which accrues at the time the shares are issued or accepted by the corporation.