Whether Donations Received by the Foreign Missionaries Affiliated with the Gospel Fellowship Association are Not Subject to Income Tax

February 14, 1994 BIR RULING NO. 062-94 21 330-92 062-94 Gospel Fellowship Association Box 120 U.P., Quezon City Attention: Ms . Brenda Garren Gentlemen : This refers to your letter dated February 18, 1993 requesting for a ruling that donations received by the foreign missionaries affiliated with the Gospel Fellowship Association are not subject to income tax. It is represented that the Gospel Fellowship Association is a non-stock, non-profit corporation organized and existing under the State of Tennessee, U.S.A. duly licensed to engage in religious activities in the Philippines and registered with the Securities and Exchange Commission; that it is a tax exempt organization pursuant to Section 26 of the Tax Code, as amended; that it has foreign missionaries assigned and performing its evangelistic ministry in the Philippines; that they derive financial support from funds in the form of cash, checks or pledges from friends and Christian churches abroad prior to their departure to the Philippines and finally, that these funds are coursed through the Gospel Fellowship Association's main office in Greenville, S.C. and then remitted to the missionaries based in the Philippines and credited to the account of the foreign missionaries concerned. In reply, please be informed that since the financial support being received by the foreign missionaries are not compensation/or salary but donations given them prior to their coming to the country and that the funds are merely coursed through Gospel Fellowship Association for the account of the foreign missionaries, said financial support are not therefore, subject to Philippine income tax. It should be understood, however, that if upon investigation, the facts as represented are found to be different, this ruling shall be considered null and void. cdtech Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue