BIR Ruling

July 24, 1975 Catholic Vicar Apostolic of the Mountain Province Bishop's Residence, Baguio City Attention: William Brasseur, D . D . Gentlemen : This refers to your application for qualification as a donee or legatee entitled to the benefits of Presidential Decree No. 507. In reply, I have the honor to inform you that Presidential Decree No. 507, allows the deduction in full only if the donation is made in favor of social welfare, cultural or charitable institutions, as defined in Section 3(a)(b)(c) of Revenue Regulations No. 8-74 implementing Presidential Decree No. 507; no part of the net income of which inures to the benefit of any of its members. aisa dc Since said Catholic Vicar Apostolic of the Mountain Province is neither a social welfare, cultural nor charitable institution, it is not one of the institutions contemplated by Presidential Decree No. 507. In other words, said Decree cannot be cited as basis of your claim that the donations to the Catholic Vicar Apostolic of the Mountain Province, a religious corporations sole, is deductible in full from the gross income of the donor or contributor. However, gifts made in favor of that religious corporation are deductible from the gross income of the donor to an amount not in excess of 6% in the case of an individual and 3% in the case of a corporation. Moreover, said gifts are exempt from the donor's gift taxes provided that not more than thirty per centum of said gift shall be used by the donee for administration purposes pursuant to Section 112 of Tax Code. cdt Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5