Tax on the Gain Derived from the Sale of Its Property

May 28, 1980 BIR RULING NO. 067-80 Messrs. Bengzon, Zarraga, Narciso, Cudala, Pecson, Azcuna & Bengson 6th Floor, Sol Building Amorsolo St., Legaspi Village Makati, Metro Manila Attention: Atty . Amando V . Faustino, Jr . Gentlemen : This refers to your letter dated November 29, 1978 requesting a ruling as to whether or not the gain to be derived by your client, the Maryknoll Sisters Parish Work, Inc., from the sale of its property is subject to tax. You have represented that your client is a religious corporation and that it sold its property located at Loyola Heights, Quezon City, the proceeds of which will be used to acquire another property on which it intends to build a modest convent for the Maryknoll Sisters. In reply thereto, I have the honor to inform you that while a corporation or association organized and operated exclusively for religious, charitable, scientific, athletic, or cultural purposes, or for the rehabilitation of veterans, no part of the net income of which inures to the benefit of any private stockholder or individual, is exempt from tax on income received by them as such, nevertheless, the income of whatever kind and character of the organization from any of its properties, real or personal , or from any of its activities conducted for profit, regardless of the disposition made of such income shall be subject to tax pursuant to Section 27 of the Tax Code, as amended. Such being the case, the gain derived by your client from the aforesaid sale of its property shall be subject to tax. Very truly yours, RUBEN B. ANCHETA Acting Commissioner