FCSSTA Foundation, Inc.

July 30, 2008 BIR RULING [DA-(DT-005) 083-08] Section 101 (A) (3); DA-618-07 FCSSTA Foundation, Inc. 86 Speaker Perez St., Quezon City Attention: Mr. Lim You Tiat President Gentlemen : This refers to your letter dated June 7, 2008 requesting for exemption from the payment of donor's tax relative to the donation in favor of FCSSTA Foundation, Inc. It is represented that FCSSTA Foundation, Inc. (Foundation) is a non-stock, non-profit association or foundation formed and organized primarily for social, civic, charitable and fraternal purposes with principal address at 86 Speaker Perez St., Quezon City and duly registered with the Securities and Exchange Commission under SEC Registration No. A200018326; that the subject parcel of land is covered by Transfer Certificate of Title No. N-187519 with an area of 800 square meters, more or less, of the Registry of Deeds for Quezon City; that a Deed of Donation dated December 19, 2001 was executed by and between Lim You Tiat, et al. as donor and FCSSTA Foundation Inc. as donee; and that the Foundation shall require funding, which shall necessarily come from gifts, donations and other contributions, given that the Foundation is not engaged in activities for profit. In reply, please be informed that inasmuch as the donee is a charitable foundation, 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 said gift shall be used by the donee for administration purposes. STaAcC 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