BIR Ruling

August 28, 1968 Dr. Gregorio Singian c/o Cardiovascular Research Institute of Manila 998 Gen. Solano St. San Miguel, Manila S i r : This is in reply to your letter of July 30, 1968 requesting information on a query stated as follows: "I represent a group who have formed a non-profit, non-stock corporation by the name of the CARDIOVASCULAR RESEARCH INSTITUTE OF MANILA which has been duly registered by the Securities and Exchange Commission. Our main objective as outlined in our By-laws, is the raising of funds for the purchase of machines, laboratory apparatus, surgical and medical equipment for the pursuit and advancement of cardiovascular research work in our country. "In our previous conversations with one of your staff, she opined that donations given to our corporation may be deductible from the income tax returns of each donor as provided for by the law on Research Institution. Kindly outline to use the conditions whereby our donors can avail themselves of this provision of the law." Section 24 of Republic Act No. 2067 provides that the National Science Development Board shall promote and, in its discretion assist in the establishment of private foundations for scientific advancement as well as specific research and development projects by private individuals, firms and institutions. All funds contributed to the support and maintenance of such foundations and their projects as well as specific research and development projects undertaken by private individuals and educational institutions, shall be tax-exempt and deductible from the donor's income tax returns, upon certification by the Board that such foundations and funds are dedicated to scientific pursuits. Pursuant to the aforestated provision of law, contributions and donations given for the support and maintenance of public or private foundation or institutions established and dedicated to scientific advancement and specific research like the CARDIOVASCULAR RESEARCH INSTITUTE OF MANILA are not subject to tax and are deductible in full from the donor's gross income for income tax purposes. However, this tax exemption can only be availed of upon certification by the National Science Development Board that such foundations and funds are in fact, dedicated to scientific purposes. cdta Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue