DEPARTMENT OF FINANCE (DOF), REPRESENTED BY ITS SECRETARY AND THE BUREAU OF INTERNAL REVENUE (BIR) REPRESENTED BY ITS COMMISSIONER, PETITIONER, VS. ASIA UNITED BANK, BDO UNIBANK, INC., BANK OF AMERICA, BANK OF COMMERCE, BDO PRIVATE BANK, INC., CITIBANK, N.A., PHILIPPINES CHINA BANKING CORPORATION, CHINATRUST (PHILS.) COMMERCIAL BANK CORPORATION, DEUTSCHE BANK AG, MANILA BRANCH, EASTWEST BANKING CORPORATION, ING BANK N.V., MANILA BRANCH, PHILIPPINE BANK OF COMMUNICATIONS, PHILIPPINE NATIONAL BANK, PHILIPPINE VETERANS BANK, PNB SAVINGS BANK, RIZAL COMMERCIAL BANKING CORPORATION, SECURITY BANK CORPORATION, STANDARD CHARTERED BANK, PHILIPPINE BRANCH, UNITED COCONUT PLANTERS BANK, HONGKONG SHANGHAI BANKING CORPORATION LIMITED-PHILIPPINE BRANCHES, HSBC SAVINGS BANK (PHILIPPINES), INC., KOREA EXCHANGE BANK, MANILA BRANCH, JPMORGAN CHASE BANK, N.A., PHILIPPINE BRANCH, UNITED OVERSEAS BANK PHILIPPINES, LAND BANK OF THE PHILIPPINES, DEVELOPMENT BANK OF THE PHILIPPINES, BANK OF THE PHILIPPINE ISLANDS, BPI DIRECT SAVINGS BANK, METROPOLITAN BANK & TRUST COMPANY, UNIONBANK OF THE PHILIPPINES, AND BDO CAPITAL AND INVESTMENT CORPORATION, RESPONDENTS