Tax Status of the "Order of the Sisters of St. Paul"

February 9, 1960 BIR RULING NO. 042-60 Mr. Hernan F. Consunji Certified Public Accountant 1096 Constancia, Sampaloc M a n i l a S i r : Reference is made to your letter dated January 29, 1960 requesting our opinion on the tax status of the "Order of the Sisters of St. Paul" under the circumstances mentioned therein which are quoted below: "The Order of the Sisters of St. Paul is a non-profit, charitable and religious organization whose members are contracted to administer and supervise the operation of a private hospital. Some nuns or sisters member of this religious organization are registered nurses, who are rendering services to the said hospital with nominal amount of compensation which is paid direct to the organization and not to any individual nun or sister. The question is whether a nun or a sister, who maybe a registered nurse, member of the Order of the Sisters of St. Paul rendering services as outlined above in addition to other professionals such as doctors and nurse employed by the said hospital, is subject to the occupation tax as prescribed by Sec. 201 of the National Internal Revenue Code." In reply to your aforesaid letter, I have the honor to inform you that only those professionals employed in hospitals and similar establishments not conducted for private gain and whose entire professional services are devoted exclusively thereto are exempt from the occupation tax. Accordingly, if the private hospital wherein the aforementioned sisters are employed as nurses is conducted for private gain, said nurses must pay the occupation tax even if they belong to a non-profit, charitable and religious organization. cdtech Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue