BIR Ruling

May 8, 1975 Atty. Antonio C. Ravelo 615 May Building Rizal Avenue, Manila S i r : In reply to your letter dated May 7, 1975, I have the honor to inform you that the following donations effected by the Commission on Ecumenical Missions and Relations of the United Presbyterian Church in the United States of America (formerly known as the Board of Foreign Missions of the Presbyterian Church in the United States of America) in favor of your client, the United Church of Christ in the Philippines, a religious corporation organized and existing under the laws of the Philippines, with principal office at 939 E. de los Santos Avenue, Quezon City, are exempt from the donor's gift tax, pursuant to Section 112 (A)(3) of the Tax Code, as amended by Presidential Decree No. 69; 1. Deed of Donation dated July 17, 1973 covering a parcel of land under OCT No. 2587 with improvements located at Catbalogan, Samar. 2. Deed of Donation dated July 17, 1973 covering a parcel of land under OCT No. 267 with improvements located at Poblacion, Tigaon, Camarines Sur. 3. Deed of Donation dated July 17, 1973 covering a parcel of land (unregistered) with improvements located at Viga, Catanduanes. cdt 4. Deed of Donation dated July 17, 1973 covering a parcel of land with a total area of 25 square meters situated in Block 287, lot 8, of Cementerio del Norte, Manila with improvements thereon. 5. Deed of Donation dated July 17, 1973 covering a parcel of land under Tax Declaration No. 8728 with improvements located at San Juan, Goa, Camarines Sur. 6. Deed of Donation dated July 17, 1973 covering a parcels of land under OCT Nos. 310, 5483, 3913, 3661 and 1806, with improvements located at Tagbilaran City. 7. Deed of Donation dated July 17, 1973 covering parcels of land under TCT No. RT-1018(622), OCT No. RO-11034(17900), TCT No. RT-1017(1147), OCT No. RO-11097(742), TCT No. RT-1019(67), TCT No. RT-1020(4627), TCT No. RT-1021(2073), TCT No. RT-103(4628), TCT No. RT-1034(4629), TCT No. RT-1035(267), OCT Nos. RO-11098(19981), RO-11096(5414), RO-11095(29281), and plan PSU-179015 with improvements all located at the Province of Labay. 8. Deed of donation dated July 17, 1973 covering a parcel of land under OCT No. RO-7461(650) with improvements located at Los Baos, Laguna. 9. Deed of Donation dated July 17, 1973 covering parcels of land under Tax Declaration Nos. 16459 and 19324 with improvements located at Ligao and Guinobatan, Albay. 10. Deed of Donations dated July 17, 1973 covering parcels of land under TCT Nos. 37643 and 17623 with improvements located at Cebu City and Minglanilla, Cebu, respectively. However, the exemption is subject to the condition that not more than 30% of the said gifts shall be used by the donee for administration purposes. cdta Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5