BIR Ruling [DA-132-05]

April 6, 2005 BIR RULING [DA-132-05] 101 (A) (3) DA-481-98 Joyful Life with Jesus Ministries, Incorporated 180 Roosevelt Ave., San Francisco del Monte Quezon City Attention: Pastor Ramon P. Agustin Chairman of the Board Gentlemen : This refers to your letter dated November 30, 2004 requesting exemption from the payment of taxes that may be imposed on the donations that may be made in your favor pursuant to Section 101(A) of the Tax Code of 1997. It is represented that Joyful Life with Jesus Ministries, Incorporated is an independent, non-stock, non-profit organization registered at the Securities and Exchange Commission on November 10, 1987 under SEC Registration No. 146387; that its main goal is to preach the good news of salvation of our Lord Jesus Christ throughout the whole part of the Philippine Islands; that in the past, it has done evangelistic and healing meetings in some Barangays in Quezon City and in some Barangays in the provinces of Pangasinan and Camarines Norte where it has four outreaches; that the main church is now located at No. 180 Roosevelt Ave., San Francisco del Monte, Quezon City; that it is holding its worship services unto the Lord every Sunday morning and Wednesday evening; that it teaches people through the Bible on how to grow in faith in God and to be good disciples of Jesus Christ; that at present, it has a feeding program for children belonging to poor families in Zambales St., Cubao, Quezon City every Sunday afternoon; that the sources of income of this Christian organization is through the giving of tithes and love offerings of the members and some friends and sympathizers, most of them are locally based; that since the organization has no affiliation with other religious organization, both local and abroad, the funds to support the operational expenses is not sufficient; and that it has about eight full-time volunteer workers, who work sacrificially with the other pastors and missionaries who are receiving a small amount of money as love gift, which is less than the minimum prescribed by the government. In reply, please be informed that inasmuch as the donee is a religious institution, donation to it is exempt from the payment of donor's tax pursuant to Section 101(A)(3) of the Tax Code of 1997, subject to the condition that not more than 30% of said gift shall be used by the donee for administration purposes. ISCaTE Moreover, the Deed of Donation executed for the purpose is not subject to the documentary stamp tax. However, the notarial acknowledgment on said deed is subject to the documentary stamp tax of P15.00 imposed under Section 188 of the Tax Code of 1997. (BIR Ruling No. DA-481-98 dated November 9, 1998) Very truly yours, Commissioner of Internal Revenue By: (SGD.) JOSE MARIO C. BUAG Deputy Commissioner Legal and Inspection Group