Request for Exemption from Donor's Tax on Donation of Shares of Stock to the Catholic Bishop of the Prelature of Ipil

June 5, 1985 BIR RULING NO. 084-85 123 (a) (c) 232-83 084-85 Gentlemen : This refers to your letter dated January 18, 1985 requesting exemption from the payment of the donor's tax on the donation of five hundred (500) fully paid and Non-Assessable Shares of the Common Class "B" Stock of the par value of Three Pesos each of Benguet Consolidated, Inc. under Stock Certificate No. PU 24924 by Mrs. Elena Von Kauffmann de Elizalde through her Attorney-in-fact, Mrs. Conchita L. Benitez in favor of the Catholic Bishop of the Prelature of Ipil, Zamboanga del Sur. cd It appears that the donee is a religious corporation sole duly organized and existing under the laws of the Philippines. In reply, please be informed that since the donee is a religious corporation sole, the aforementioned donation is exempt from the payment of the donor's gift tax pursuant to Section 123(a)(3) of the Tax Code of 1977, as amended. However, the exemption from the donor's gift tax is subject to the condition that not more than 30% of the said gifts shall be used by the donee for administration purposes. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner