The Local Superior of the Congregation of the Sacred Hearts, Inc.

November 23, 2009 BIR RULING [DA-(DT-064) 692-09 101 (A) (3); DA-329-2008 The Local Superior of the Congregation of the Sacred Hearts, Inc. 152 9th Street, Barangay Mariana District IV Quezon City Attention: Fr. Noel Flaviano, SSCC Local Superior Gentlemen : This refers to your letter dated October 12, 2009 requesting for a ruling to the effect that donations received by your institution are exempt from the payment of donor's tax pursuant to Section 101 (A) (3) of the Tax Code of 1997. It is represented that The Local Superior of the Congregation of the Sacred Hearts, Inc. with Tax Identification Number 209-714-138 is a corporation sole registered with the Securities and Exchange Commission under SEC Registration No. ANO91-195389 dated September 5, 1991; and that the purpose for which the corporation sole was formed is for the administration of the affairs, properties and temporalities of its church. CSTEHI In reply, please be informed that inasmuch as the donee is considered a non-stock non-profit religious organization, donations to it are exempt from the payment of donor's tax pursuant to Section 101 (A) (3) of the Tax Code of 1997, as amended, subject to the condition that not more than 30% of said gift shall be used by the donee for administration purposes. Moreover, the Deed of Donation is not subject to 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 Tax Code of 1997, as amended. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation it will be disclosed that the facts are different, then this ruling shall be considered null and void. DcTSHa Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service