Exemption from the Donor's Tax

April 12, 1989 BIR RULING NO. 067-89 94 (a) (3) 397-88 067-89 M a d a m : This refers to your letter dated March 31, 1989 requesting in effect exemption from the donor's tax of the donation you and your son, Father Luis Esteban Latorre, made on March 14, 1989 of you real properties covered by TCT Nos. (217379) S-62523 and S-109199 situated in the Barrio of Alabang, Municipality of Muntinlupa, Metro Manila and Makati, Metro Manila respectively in favor of Porfirio D. Latorre Memorial & Fr. Luis Esteban Latorre Foundation, Inc. casia In reply, I have the honor to inform you that since the Porfirio D. Latorre Memorial & Fr. Luis Esteban Latorre Foundation, Inc. is a non-stock, non-profit scientific, research, cultural and civic foundation, paying no dividends, governed by trustees who receive no compensation and devoting all its income, whether student's fees or gifts, donations, subsidies or other forms of philanthropy, to the accomplishment and promotion of the purposes enumerated in its articles of incorporation, the aforementioned donation is exempt from the payment of donor's tax, pursuant to Section 94(a)(3) of the Tax Code, as amended, provided that not more than thirty per centum (30%) of said gifts shall be used by the donee for administration purposes. cd Very truly yours, (SGD.) JOSE U. ONG Commissioner