Bread of Life Ministries, Incorporated

March 19, 2008 BIR RULING [DA-182-08] Section 30 (E); DA-329-2005 Bread of Life Ministries, Incorporated Crossroad 77 Mother Ignacia Avenue corner Scout Reyes St., Quezon City 1103 Attention: Mr. Pedro F. Galvez Corporate Secretary Gentlemen : This refers to your letter dated January 29, 2008 requesting for exemption from the payment of donor's tax relative to the donations in favor of the BREAD OF LIFE MINISTRIES, INCORPORATED. Documentary evidence submitted disclosed that the BREAD OF LIFE MINISTRIES, INCORPORATED is a non-stock, non-profit religious organization registered with the Securities and Exchange Commission under SEC Reg. No. 111774 dated December 8, 1983; that the aims and objectives for which the corporation is organized, are as follows, viz.: 1. To propagate the Christian life and to spread the Gospel of Jesus Christ as revealed through the Holy Scriptures; 2. To provide for teaching, preaching and foster in the growth of Christianity. To license and appoint the ministers destined by God; to carry out the work of evangelism; to promote missionary work in the Philippines and foreign countries; to carry on the organization of churches and foster their development; that the central church, located at Quezon City, Metro Manila has a congregation of over 12,000; that the churches are located in all major cities of the Philippines, Brunei and Myanmar in Southeast Asia, Los Angeles, San Francisco and San Diego, California, in France and the Netherlands in Europe; and that you are consistently receiving some donations in cash or in kind from your church members for the purposes of the ministry. In reply, please be informed that inasmuch as the donee is a religious organization, the aforementioned donations are 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. Moreover, the Deed of Donation is not subject to the documentary stamp tax prescribed under Section 196 of the Tax Code of 1997, but only to the documentary stamp tax of P15.00 imposed under Section 188 of the same Tax Code. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be ascertained that the facts are different, then this ruling shall be considered null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service