Mr. Enrique Robles

February 24, 1977 Mr. Enrique Robles Malaya, Pililla Rizal S i r : This refers to your letter dated October 11, 1976 requesting a ruling as to whether or not the donation of a parcel of land which is covered by a Deed of Donation executed on October 28, 1929 is subject to the donor's and donee's gift taxes. In reply thereto, I have the honor to inform you that our statutes imposed a tax upon the transfer of property by gift intervivos made on or after July 1, 1939. (annotations and Jurisprudence on the National Internal Revenue Code, as amended, by Jose Araas Vol. 2, p. 118, 1969 Ed.) Accordingly, the donation of a parcel of land which is covered by a Deed of Donation executed on October 28, 1929 is not subject to the donor's and donee's gift taxes. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."