GreenEarth Heritage Foundation Inc.

September 15, 2009 BIR RULING [DA-(DT-053) 543-09] 101 (A) (3); DA-618-2004 GreenEarth Heritage Foundation Inc. 6 Mola St., La Paz, Makati City Attention: Ms. Mylene V. Matti, MD Founder and Executive Director Gentlemen : This refers to your letter dated July 1, 2009 requesting in effect, for a ruling that the donation of parcels of land by Luis R. Villafuerte in favor of GreenEarth Heritage Foundation, Inc. (GEHFI) is exempt from donor's tax and documentary stamp tax. Documents submitted show that Luis R. Villafuerte with residence and postal address at 5226 Fahrenheit St., Palanan, Makati City is the absolute owner of two (2) parcels of land situated at Barangay Calumpang, Municipality of San Miguel, Province of Bulacan covered by Transfer Certificates of Title (TCT) No. T-30745 and T-30746. On the other hand, GEHFI with Tax Identification No. (TIN) 007-298-144-000, is a non-stock, non-profit corporation duly registered with the Securities and Exchange Commission (SEC) under SEC Reg. No. CN 200907344 dated May 22, 2009. The purpose for which the foundation was formed is to become an institutional vehicle for applying scientific and technological methods and practices in order to experiment and conduct pilot projects in organic crop and livestock production under free range and pastured systems, employing natural feeding techniques under globally accepted standards of sustainability. On June 22, 2009, a Deed of Donation was executed by and between the afore-stated parties, whereby Luis R. Villafuerte donates the subject properties to GEHFI. In reply, please be informed that inasmuch as the donee is a research organization the above-stated donation is exempt from the payment of donor's tax pursuant to Section 101 (A) (3) of the Tax Code of 1997. HAISEa Moreover, the subject donation will not be subject to the documentary stamp tax prescribed under Section 196 of the Tax Code of 1997, but the Deed of Donation shall be subject to the notarial acknowledgment of P15.00 imposed under Section 188 of the same Tax Code, as amended. 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 as null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service