BIR Ruling

March 17, 1967 Messrs. Ozaeta, Gibbs and Ozaeta Attorneys at Law P.O. Box 758, Manila Gentlemen : This refers to your letter dated March 17, 1966 requesting that your client, A.A. Allen Revivals, Inc., corner Lauan and Molave Streets, Project 3, Quezon City, be exempt from the payment of income tax and filing of the corresponding income tax return under Section 27(e) of the National Internal Revenue Code. It appears that A.A. Allen Revivals, Inc. (hereinafter referred to as the Corporation) is a non-stock and non-profit corporation formed and organized under the laws of the state of Texas, U.S.A.; that the purposes for which the Corporation was organized are to carry on the functions of a church including the regular conduct of religious worship and the ministration of sacerdotal functions, preaching of the gospel and the training, ordaining and sending forth of ministers to evangelize or to pastor other and subordinate churches, to support and maintain all benevolent, charitable, educational or missionary undertakings of the Corporation, to obey in its capacity as a Christian church organization the Great Commission as stated in the Holy Bible, teaching and practicing the time honored doctrines of the Christian Faith, and to establish, maintain and use such departments, institutions, installation, media, equipment and policies as may be considered advisable and necessary for the pursuance, furtherance and maintenance of a traveling evangelistic institution and church; that income of the Corporation consists of the offerings or contributions given by devotees who are interested in the Corporation's religious work; that the property of the Corporation is irrevocably dedicated to religious and charitable purposes, and upon liquidation, dissolution, or abandonment, shall be distributed to valid and authentic religious or charitable organizations holding tax exempt status and which are recognized as such by the Treasury Department of the United States Government; and that under no circumstances will the income or assets of the Corporation inure to the personal benefit of any individual. Based on the foregoing facts, the A.A. Allens Revivals, Inc. is an exempt organization within the purview of Section 27(e) of the Tax Code. Accordingly, it is exempt from the payment of income tax. The Corporation is, however, subject to income tax on income derived from any of its properties, real or personal, or from any activity conducted for profit, regardless of the disposition made of such income. If it has not earned any taxable income, it is also exempt from filing income tax return. LexLib Moreover, the Corporation is required to file on or before April 15, of each year, an annual information return under oath, stating its gross income and expenses incurred during the preceding year, and a certificate showing that there has not been any substantial change in its By-Laws, Articles of Incorporation, manner of operation and activities as well as sources and disposition of income pursuant to Revenue Regulations No. 7-64 dated November 4, 1964. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue