More Than Conquerors Fellowship Int'l., Inc.

September 9, 2009 BIR RULING [DA-(DT-047) 522-09] 101 (A) (2); DA-481-98 More Than Conquerors Fellowship Int'l., Inc. Sto. Rosario, Malolos, Bulacan Attention: Mr. Leomer S. Clavio Corporate Secretary Gentlemen : This refers to your letter dated June 22, 2009 requesting for exemption from the payment of donor's tax under Section 101 of the Tax Code of 1997. Documents submitted disclosed that More Than Conquerors Fellowship Int'l., Inc. (MTCF) is a non-stock non-profit religious corporation; that it is registered with the Securities and Exchange Commission (SEC) under SEC Registration Certificate No. 125473 dated May 16, 2007; that it is also registered with the Bureau of Internal Revenue (BIR) with Taxpayers Identification No. 228-413-107; that MTCF operates as a Born-Again Church since 1985; that a Deed of Donation was executed by and between More Than Conquerors Fellowship International, Inc. on April 21, 2007 wherein it was stated therein that Mr. Rolando Panganiban is the registered owner in fee simple of a certain parcel of land situated in Malolos, Bulacan, covered by Transfer Certificate of Title No. T-308359 of the Registry of Deeds of the Province of Bulacan and more particularly described as follows: "A parcel of land (Lot No. 1394 of the Cad. Survey of Malolos), with the improvements thereon, situated in the Mun. of Malolos. Bounded on the NE., by Lot Nos. 8834, 1395 and 1395; * on the SE., by Lot Nos. 1395 and 1396; on the SW., by Lot Nos. 1397 and 1393; and on the NW., by Lot No. 21. Beginning at a point marked "1" on plan, being S. 61 deg. 45'E., 255.99 m. from BBM No. 45; S. 57 deg. 07'W., 22.57 m. to point 2; S. 28 deg. 08'E., 10.97 m. to point 3; S. 55 deg. 57'W., 4.80 m. to point 4; S. 27 deg. 07'E., 2.79 m. to point 5; S. 59 deg. 54'W., 18.68 m. to point 6; N. 33 deg. 58'W., 15.63 m. to point 7; N. 26 deg. 50'W., 7.60 m. to point 8; N. 54 deg. 57'E., 46.61 m. to point 9; S. 33 deg. 30'E., 12.05 m. to the point of beginning; containing an area of EIGHT HUNDRED AND THIRTY EIGHT (838) SQ. METERS, more or less. All points referred to are indicated on the plan; bearings true; decl. 0 deg. 30'E., date of survey, May 1921-Nov. 1922." SETaHC In reply, please be informed that inasmuch as the donee is a religious organization and the real property subject of said donation shall be exclusively utilized for its religious activities, the aforesaid donation is exempt from the payment of donor's tax pursuant to Section 101 (A) (2) of the Tax Code of 1997. Moreover, the Deed of Donation executed for the purpose is not subject to the documentary stamp tax. However, the notarial acknowledgment on said deed is subject to the documentary stamp tax of P15.00 imposed under Section 188 of the Tax Code of 1997. (BIR Ruling No. DA-481-98 dated November 9, 1998) Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service