Request for Exemption under Section 94(a)(3) of the Tax Code, of the Donations of Two (2) Parcels

March 12, 1992 BIR RULING NO. 076-92 94 (a) (3) 145-91 076-92 Quezon City Filipino-Chinese Foundation, Inc. 62 Kitanlad Street Quezon City Attention: Mr . Julio Tan Corporate Secretary Gentlemen : This refers to your letter dated December 5, 1991 requesting exemption under Section 94(a)(3) of the Tax Code, of the donations of two (2) parcels of land situated in Quezon City, covered by TCTs Nos. RT-26951 and RT-26952 both of the Registry of Deeds for Quezon City made by the Filipino-Chinese Chamber of Commerce in favor of Quezon City Filipino-Chinese Foundation, Inc. by virtue of a Deed of Donation executed on December 11, 1991. Investigation conducted by this Office disclosed that the Quezon City Filipino-Chinese Foundation, Inc. is a non-stock, non-profit educational, charitable and social welfare organization duly registered as donee institution under Batas Pambansa Blg. 45, amending Section 29(h) of the Tax Code, as implemented by BIR-NEDA Regulations Nos. 1-81 and 10-82. In reply, please be informed that inasmuch as the donee is an educational, charitable and social welfare organization, the aforementioned donation is exempt from the payment of donor's tax pursuant to Section 94(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. aisadc Very truly yours, JOSE U. ONG Commissioner of Internal Revenue