BIR Ruling

March 14, 1977 Welding Research & Training Institute, Inc. Poaco Building No. 30 MacArthur Highway Malabon, Rizal 3118 Attention: Dr . Augusto Santos-Ocampo President Gentlemen : This refers to your letter requesting that you be allowed to avail of the tax exemption benefits on gift and donations. Investigation conducted by this Office disclosed that the Institute is a non-stock, non-profit association duly registered with the Securities and Exchange Commission and that the purposes for which the Corporation is formed are; to contribute to the Manpower Development Program of the government by training men in assimilating correct welding and cutting techniques in gas and electric welding; to contribute to the rapid development of the industries where welding is a major activity by providing them with skilled workers; and to promote and encourage researches on modern principles of both gas and electric welding. It appears also that Institute pays on dividends, is governed by trustees who receive no compensation, and devote all its income, to the accomplishment and promotion of the purposes enumerated in its Articles of Incorporation. In reply, I have the honor to inform you as that Institute is a research institution, gifts to it are exempt from the donor's gift tax in accordance with Section 112(a)(3) of the Tax Code, provided that not more than 30% of said gifts are used by that Institute-donee for administration purposes. However, contributions to that Institute are not deductible from the gross income of the contributor for income tax purposes, since there is no law authorizing such deduction. aisadc Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3