BIR Ruling

August 14, 1975 Messrs. Quasha, Asperilla, Zafra, Tayag and Ancheta Lawyers Don Pablo Building 114 Amorsolo St., Makati, Rizal Attention: Mr . A . R . Rance For the Firm Gentlemen : In reply to your letter of the 7th instant, I have the honor to inform you that the transfer by way of donation of a parcel of land covered by T.C.T. No. 11601 of the Land Registry of the City of Manila, by your client the Bishop of the Missionary District of The Philippine Islands of the Protestant Episcopal Church In the United States of America, a religious corporation sole organized and existing under the laws of the Philippines, as donor, in favor of the Iglesia Filipina Independiente, a religious corporation organized and existing under Philippine laws, as donee, is exempt from the donor's gift tax, provided that more than 30% of said donation shall be used by said donee for administration purposes. (Section 112(a)(3), Tax Code, as amended by Presidential Decree No. 69). cdta Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN 1601-593-5