Kintanar Jamon Paruñgo & Ladia Law Firm

August 11, 2009 BIR RULING [DA-(DT-041) 454-09] Section 101 (A) (3); BIR Ruling No. 353-93; S30-056-2001; DA-120-07 Kintanar Jamon Parugo & Ladia Law Firm Suite 11-B, Belvedere Tower, San Miguel Avenue, Ortigas Center, Pasig City Attention: Atty. Jose Atendido Parugo Atty. Jacky P. Makiling-Silva Gentlemen : This refers to your letter dated June 29, 2009 requesting for exemption from the payment of donor's tax relative to the donation in favor of the Christ In You Christian Baptist Mission, Inc. HIAESC Documents submitted disclosed that the Christ In You Christian Baptist Mission, Inc., with Taxpayer Identification No. 006-974-919-000, is a non-stock, non-profit religious organization registered with the Securities and Exchange Commission under SEC Reg. No. CN200802496 dated February 19, 2008; that the purpose for which this religious corporation was incorporated is for the administration of its affairs, properties and temporalties; that its funds primarily come from "faith promises", tithes and donations; that Deed of Donation was executed by Ricardo Tan, Leigh Ang Tan, Mervin Ang Tan, and Kathryn Ang Tan, as donors of a parcel of land as well as all improvements thereon, located in Quezon City covered by Transfer Certificate of Title No. 103861 of the Registry of Deeds of Quezon City, in favor of Christ In You Christian Baptist Mission, Inc., as donee; and that the donation was due to the generosity and benevolence of the donors to the donee. 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. (BIR Ruling No. DA-120-07 February 23, 2007) 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. aCcHEI Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Services