BIR Ruling

February 3, 1976 Asian Institute of Insurance Inc. 5th Floor, PPL Building U. N. Avenue, Manila Attention: Mr . E . S . Sevilla Executive Officer Gentlemen : This refers to your letter dated December 4, 1975 requesting exemption from the payment of income tax and the filing of the corresponding income tax return under Section 27(g) of the Tax Code. acd In reply, I have the honor to inform you that, in a letter dated December 19, 1974 this office ruled that all bequests, gifts and donations to that institute are exempt from donor's and estate taxes and that the donor may claim as deductions in full such gifts and contributions for income tax purposes pursuant to Presidential Decree No. 507. The exemption was granted on the basis of our findings that the Institute is a corporation or association organized and operated exclusively for cultural purposes, no part of the net income of which inures to the benefit of any of its members. In view thereof, since that Institute falls within the purview of a corporation organized and operated exclusively for cultural purposes, pursuant to Section 27(e) of the Tax Code, it is exempt from the payment of income tax on income earned by it as such corporation and, therefore, need not file an income tax return covering such income. However, it is 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 thereof, which income should be returned for taxation. And even if no taxable income is earned, it should file on or before April 15 of each year, an annual information return stating under oath its gross income and the sources thereof and the expenses incurred during the preceding year, attaching thereto (a) a profit and loss statement; (b) a balance sheet; and (c) a certificate attesting that there has not been any change in its By-Laws, Articles of Incorporation, and its activities and manner of operation. aisadc 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."