BIR Ruling

May 29, 1974 Messrs. Quasha, Asperilla, Zafra, Tayag & Ancheta L a w y e r s CCPO Box 210, Makati, Rizal D-708 Attention: Atty . A . P . Rance Gentlemen : This refers to your letter dated May 18, 1974 requesting exemption from the donor's gift taxes the donation executed in favor of your client, the Missionary District of the Philippine Islands of the Protestant Episcopal Church in the United States. aisa dc It is represented that your client is a religious corporation sole organized and existing under the laws of the Philippines, with principal offices at 281 E. Rodriguez, Sr. Blvd. Quezon City; that the mother Episcopal Church of the said Missionary District is the Domestic and Foreign Missionary Society of the Protestant Episcopal Church located in the United States of America; that the mother Episcopal Church has real estate properties in the Philippines, specifically in Manila, Quezon City, Baguio City, Zamboanga City, Cotabato and in the Mountain Province; that said properties are presently occupied by the local Missionary District and are exclusively used for religious purposes; that the mother Episcopal Church has executed a Deed of Donation on April 24, 1974, in the United States, in favor of your client, of all of its properties located in the Philippines. In reply, I have the honor to inform you that pursuant to Section 112(b)(2) of the Tax Code, as amended by Presidential Decree No. 69, gifts or donations made in favor of a religious corporation are exempt from the donor's gift tax. Such being the case, the above-mentioned donation made in favor of the Missionary District of the Philippine Islands of the Protestant Episcopal Church, a religious corporation, is exempt from the donor's gift tax. However, it is a condition for the enjoyment of the tax exemption that not more than 30% of the gift shall be used for administration purposes. casia Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN 1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."