BIR Ruling

January 22, 1969 Mr. Alfredo F. Martinez c/o Machinery & Engineering Supplies, Inc. Ayala Avenue corner Kamagong Makati, Rizal S i r : In reply to your letter dated January 22, 1969, I have the honor to inform you that the trustee of a qualified pension plan or employees' trust may, without affecting the exemption of the trust income under Section 56(b) of the Tax Code as amended, land any part of the trust's income or corpus or make any substantial purchase of securities or any other property to or from the employer corporation provided that such loan is with adequate documented security and reasonable rate of interest and provided further that any such purchase is for not more than an adequate and full consideration in money or money's worth. cdta Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue