Franciscan Sisters of the Immaculate, Inc.

March 7, 2007 BIR RULING [DA-141-07] Section 101 (A) (3); BIR Ruling No. DA-602-99 & DA-072-01 Franciscan Sisters of the Immaculate, Inc. Ave Maria Road, Maligaya Park Subdivision Novaliches, Quezon City Attention: Rev. Mo. Ma. Joanna Paula Pia (Grace) C. Maneja General Delegate-Philippine Mission Gentlemen : This refers to your letter dated February 28, 2007 requesting for a Certificate of Exemption in paying taxes for purposes of transferring the Certificates of Title in the name of your congregation. IHTASa As represented, The Mission of the Immaculate, Inc. is a non-stock, non-profit religious corporation registered with the Securities and Exchange Commission (SEC) under SEC Registration No. 177965 issued on December 21, 1999. On January 9, 2007, Isabelita Sibulo vda. de Lahom with address at J. Miranda Avenue corner Park St., Naga City executed a Deed of Donation in favor of The Mission of the Immaculate, Inc. over two (2) parcels of land more particularly described as Lot No. 7 and 8 of the subdivision plan Psd-009199, situated in Carolina, Naga City and covered by Transfer Certificate of Title No. 19210 and 19211, respectively. The above-described real properties were donated by Isabelita Sibulo vda. de Lahom upon learning that the congregation needed a land wherein it can construct a new convent. In reply, please be informed that inasmuch as the donee is a religious institution, the aforementioned donation 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 the said gift shall be used for administration purposes. The Register of Deeds shall, however, annotate this condition at the back of the Transfer Certificates of Title because failure to comply with the said condition shall be a ground for the revocation of the donation pursuant to Article 764 of the New Civil Code. ESaITA Moreover, the aforesaid Deed of Donation is not subject to documentary stamp tax prescribed under Section 196 of the Tax Code of 1997, but only to the documentary stamp tax of PhP15.00 imposed under Section 188 of the same Code. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered as null and void. HaIESC Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service