BIR Ruling

October 24, 1973 Rev. Joseph Gallagher Society of St. Columban 1857 Singalong, Manila Revered Father : This refers to your letter dated October 23, 1973 requesting information as to the applicability of Presidential Decree No. 213 to the members of the Society. cdtech From your letter and the oral explanation made on your operations, it appears that members of the Society do not receive any fixed emolument as compensation for services rendered. The Society's operational expenses, which include medical care, clothing, food, transportation, travel for home leave as well as the finances needed for your apostolate here come from donations from people in Ireland, England, Australia and the United States. The Society has acquired real and personal properties in furtherance of its apostolate. It was verbally represented that while some of the cars, jeeps or motorcycles were registered in the name of the members, such registration was made purely for convenience and ownership thereof vests with the Society. In reply, I have the honor to inform you that in the light of the foregoing representation, it is the opinion of this Office, as it hereby holds, that the members of the Society are not covered by Presidential Decree No. 213. It may be stated in this connection, however, that should any member in his personal capacity be situated in any of the circumstances enumerated in Section 45(a)(3) of the Tax Code, such member is covered by the Decree. acd Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5