BIR Ruling

April 22, 1974 Atty. Isaac S. Puno, Jr. R-213 Forum Building Rizal Ave. Cor. Lope de Vega St. Manila S i r : This refers to your letter dated April 15, 1974 requesting exemption from the donor's gift tax the donation of three (3) parcels of land covered by Transfer Certificates of Title Nos. 28791, 45084 and 45085, together with all the existing improvements thereon, located in the Municipality of Naic, Cavite. cdta It is represented that the Deed of Donation covering said real properties was executed on March 28, 1974 by the spouses Andres G. Grandes and Primitiva Salazar Grandea, thru their attorney-in-fact, Rev. La Verne D. Mercado, as the DONOR, in favor of the Philippines Annual Conference of the United Methodist Church, a non-profit, non-stock, religious corporation organized and existing under the laws of the Philippines with principal office at 900 United Nations Avenue, Manila, as the DONEE. In reply, I have the honor to inform you that, pursuant to Section 112 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 abovementioned donation made in favor of the Philippines Annual Conference of the United Methodist 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. aisa dc 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."