Which of the following are rights or powers of the BIR that can prescribe?

• A. Right to assess deficiency tax
• B. Right to collect assessed deficiencies
• C. Right to pursue administrative, civil, and criminal action against a taxpayer
• D. All of the above

Answer: (D)

Prescription limits the time the BIR has to act, and this applies to the main ways it can interact with a taxpayer: assessing deficiency tax, collecting any deficiency that’s assessed, and pursuing administrative, civil, or criminal actions. Each of these powers can lapse if the BIR doesn’t act within the statutory period, with certain exceptions (such as fraud or concealment) that can pause or extend the limit. Because all three capabilities—the ability to assess, the ability to collect, and the ability to pursue actions—are subject to prescription, the correct choice is that all of the above apply.