Salesian Missionaries of Mary Immaculate, Inc.

October 23, 2008 BIR RULING [DA-(DT-017) 340-08] Section 101 (A) (3); S30-056-2001 Salesian Missionaries of Mary Immaculate, Inc. 5 Cavalier Street, East Fairview Quezon City Attention: Sister Mary Michael Secretary Treasurer Gentlemen : This refers to your letter dated August 8, 2008 which was received by this office by way of 1st Indorsement dated August 21, 2008 by Revenue Region No. 7, Revenue District Office No. 28, Novaliches, Quezon City, requesting for exemption from the payment of taxes relative to the donations made to it. It appears that Salesian Missionaries of Mary Immaculate, Inc. is a non-stock, non-profit religious organization registered with the Securities and Exchange Commission under SEC Registration No. CN200801946 dated February 8, 2008; that the members of the religious congregation have no professional activities and have no salary; that you live by small gifts from friends and benefactors and the small subsidy from your Generalate; that you are involved in social activities by helping the poor children for their education, concentrating on sick children for their medical treatment which you do by economizing with the small gifts you receive from friends and benefactors; and that you would like to be exempted from tax on the donations to you, hence this request. In reply, please be informed that Section 101 (A) (3) of the Tax Code of 1997, as amended provides: "SEC. 101. Exemption of Certain Gifts. The following gifts or donations shall be exempt from the tax provided for in this Chapter: HcDSaT (A) In the Case of Gifts Made by a Resident. (1) . . . (2) . . . (3) Gifts in favor of educational and/or charitable, religious, cultural or social welfare corporation, institution, accredited non-government organization, trust or philanthropic organization or research institution or organization: . . ." Accordingly, inasmuch as the donee is a religious organization, the aforementioned donation is exempt from the payment of donor's tax pursuant to Section 101 (A) (3) 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 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