Creencia Carillo & Baldovino

July 17, 2007 BIR RULING [DA-387-07] Creencia Carillo & Baldovino Suite 1905-C, East Tower, Philippine Stock Exchange Centre Exchange Road, Ortigas Business Center 1605 Pasig City Attention: Atty. Edwin M. Carillo Gentlemen : This refers to your letter dated March 26, 2007 requesting on behalf of your client, Caleruega Philippines Foundation, Inc. ("CPFI") for an extension of the tax exemption granted to it under BIR Ruling No. S30-018-2006 dated April 10, 2006, for another year counted from April 10, 2007, in order for CPFI to work on the transfer of the title to the donated property in its name. As represented, Virra Realty Development Corporation (donor) formalized its donation of that real property situated in Brgy Caylaway, Batangas and covered by Transfer Certificate of Title No. T-40327 of the Register of Deeds of Batangas with an area of 32,234 square meters in favor of the Dominican Province of the Philippines, Inc. (DPPI). CPFI was created by DPPI's officers as a religious corporation to run the affairs of the Church and its other related religious activities and programs. In the process of transferring the title of the subject property in its name, CPFI failed to use the aforesaid BIR ruling exempting the said donation from donor's tax because CPFI's application for realty tax exemption before the Assessor's Office of Nasugbu, Batangas remains pending. In reply, please be informed that your request is granted considering that the transfer of the above described property to CPFI is beset with difficulties and circumstances beyond its control. Accordingly, the effectivity of BIR Ruling No. S30-018-2006 dated April 10, 2006 granting exemption from donor's tax on the transfer of the subject real property is hereby extended for another year or until April 10, 2008. TSCIEa 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. Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service