BIR Ruling

May 31, 1977 Conservative Baptist Pact, Inc. 89-C West Avenue Quezon City Attention: Rev . Father Federico M . Magbanua, Jr . President and Chairman of the Board of Trustees Gentlemen : This refers to your request for exemption from the payment of income tax and the filing of the corresponding income tax return under Section 27(e) of the Tax Code. Investigation conducted by this Office disclosed that the Conservative Baptist Pact, Inc., is a non-stock, non-profit corporation duly registered with the Securities and Exchange Commission; that the purposes for which the corporation is formed are: 1) to assist individual churches in purchasing suitable property to serve as construction sites for chapels, and/or church school classrooms, and/or pastor's quarters; 2) to assist church groups in the construction of chapels, and/or church school classrooms and/or pastor's quarters; and 3) through the above means to encourage church stability, provide incentive for growth, and strengthen church fellowships; that the corporation shall be maintained by contributions, gifts and subsidies, or other forms of philanthropy and that no part of its net income inures or may inure to the benefit of any member or individual. In view thereof, this Office is of the opinion and so holds that the Conservative Baptist, Pact, Inc., falls within the purview of an organization organized for purely religious purposes as contemplated by Section 27(e) of the Tax Code. Accordingly, it is exempt from the payment of income tax. It is however, subject to income tax on income derived from any of its properties, real or personal or any activity conducted for profit, regardless of the disposition made of such income. Moreover, it is required to file on or before April 15 of each year a profit and loss statement and balance sheet with the annual information return under oath, stating its gross income and expenses incurred during the year and a certificate showing that there has not been any change in its By-Laws, Articles of Incorporation, manner of operation and activities as well as sources of disposition of income. cdta Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-P4519-F2828-A-8