Request for Exemption from Payment of Donor's Tax on Donation of Parcel of Land to the Roman Catholic Archbishop of Manila

June 17, 1986 BIR RULING NO. 075-86 104 84-85 075-86 Gentlemen : This refers to your letter dated November 19, 1984 requesting exemption from the payment of donor's tax on the donation of a parcel of land located in Novaliches, Quezon City, covered by TCT No. 157769, made by spouses Victor T. Galang and Zenaida Afable-Galang, in favor of your client, the Roman Catholic Archbishop of Manila, by virtue of a Deed of Donation executed on September 5, 1984. It appears that the Roman Catholic Archbishop of Manila, is a religious corporation sole duly organized and existing under the laws of the Philippines. In reply, please be informed that inasmuch as the donee is a religious corporation, the aforementioned donation is exempt from the payment of donor's tax pursuant to Section 104(a)(3) (formerly Section 123(a)(3)) of the Tax Code, as amended, subject to the condition that not more than 30% of said gift shall be used by the donee for administration purposes. cdta Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner