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St. Francis Learning Center

BIR Ruling [DA-610-07] • Bureau of Internal Revenue (BIR) Issuances • Rulings (Unnumbered) • Dec 4, 2007

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December 4, 2007 BIR RULING [DA-610-07] Section 24 (A) & 32 BIR Ruling No. 015-94, DA-442-97 & DA-095-03 St. Francis Learning Center Nibangon, Mangan-Vaca Subic, Zambales Attention: Sr. Mary Francis Borje, SFIC Gentlemen : This refers to your letter dated November 27, 2007 requesting for a certification that Sr. Josephine Ambatali, SFIC and Sr. Esperanza Vistro, SFIC are eligible for tax exemption. As represented, Sr. Josephin Ambatali, SFIC and Sr. Esperanza Vistro, SFIC are members of the Franciscan Sisters of the Immaculate Conception with address at Mangan-Vaca, Subic, Zambales. As religious sisters, they do not own properties and do not receive income. TADcCS The certification/ruling is for purposes of expediting the process of land titling for the use of St. Francis Learning Center, a charitable school for Aetas in Zambales. Since as represented, Sr. Josephine Ambatali, SFIC and Sr. Esperanza Vistro, SFIC do not derive any personal income from their pastoral ministry/missionary work, they are not subject to income tax prescribed under Section 24 (A) of the Tax Code of 1997. 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. DIEACH Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service

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