BIR Ruling

November 25, 1976 Corporation Organized for Scientific Advancement and Scientific Pursuits 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 of the Tax Code, and your application for qualification as a donee or legatee entitled to the benefits provided for in Presidential Decree No. 507. Investigation conducted by this Office disclosed that the National Science Development Board (NSDB) has certified under Certification No. 74-F-23 dated August 29, 1974 that you are organized and is being operated for scientific pursuits within the meaning of Section 24 of Republic Act No. 2067, as amended. In reply thereto, I have the honor to quote hereunder Section 24 of Republic Act No. 2067, as amended by Republic Act No. 3589: "Sec. 24 The Board shall promote and, in its discretion, assists in the establishment of private foundation 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. All income of whatever kind and character which such foundations may derive from any or their properties, real or personal, or from their investments shall also be tax-exempt." In view thereof, considering the certification issued by the NSDB to the effect that you have been determined by said Board to have been organized for scientific advancement and that you and your funds are dedicated to scientific pursuits within the contemplation of Republic Act No. 2067, as amended by Republic Act No. 3589, this Office is of the opinion as it hereby holds that you are entitled to all the benefits and privileges provided for by said Act, as follows: 1. All funds contributed to the support and maintenance of that Corporation and its projects shall be exempt from the donor's taxes; 2. All income of whatever kind and character which that Corporation may derive from any of its properties, real or personal, or from its investments shall be tax-exempt; 3. The grants, bequests and donations received by that Corporation are exempt from income tax; and 4. All such grants, bequests and donations made in favor of that Corporation are deductible in full from the gross income of the donors without the limitations provided for in Section 30(h) of the Tax Code, as amended. cdtech