BIR Ruling

April 13, 1976 Hope Christian Foundation, Inc. 2nd Floor, 1007 United Nations Ave., Manila, P.O. Box 3812 Attention: Mr . Dalton T . Chen Chairman Gentlemen : This refers to your letter dated December 13, 1975 requesting clarification on the penultimate paragraph of our letter dated December 17, 1974 to the effect that "beginning January 1, 1974 you are no longer exempt from income taxes and therefore, you are required to file the corresponding corporate income tax return and pay the tax due thereon, pursuant to the provisions of Presidential Decree No. 305" In reply thereto, I have the honor to inform you that the abovementioned ruling is based on the fact that according to your Articles of Incorporation, one of the purposes for which you are organized is "to establish, maintain and operate schools." However, if as represented you have not yet operated any school, then you are not yet taxable under Presidential Decree No. 305; and inasmuch as you are a religious organization, exempt from income tax, pursuant to Section 27(e), you need not file an income tax return, unless you derive income from property or from any activity conducted for profit, in which case, you should return such income. However, even if you do not earn income which is taxable under the law, you should file an information return on or before April 19, 1976. Very truly yours, CONRADO P. DIAZ Acting Commissioner of Internal Revenue TAN-1182-568-4