BIR Ruling No. 090-83

May 23, 1983 BIR RULING NO. 090-83 Gentlemen : This refers to your letter dated March 16, 1983 requesting exemption from the payment of donor's gift tax of the donation of a parcel of land situated in San Juan, Metro Manila, consisting of one thousand two hundred sixty four square meters more or less, together with the improvement erected thereon, covered by Transfer Certificate of Title No. 15436 of the Registry of Deeds of the Province of Rizal, made by the spouses Domingo Franco and Ester B. Franco in favor of your client, Little Lamb Christian Foundation, Inc., by virtue of a Deed of Donation executed on September 22, 1982. It appears that the Little Christian Foundation, Inc. is a corporation duly organized and existing under the laws of the Philippines for purely religious purposes as contemplated by Section 27(e) of the National Internal Revenue Code, as amended. In reply, I have the honor to inform you that as the donee is a religious corporation, the aforementioned donation is exempt from the payment of donor's gift tax pursuant to Section 123(a)(3) of the Tax Code of 1977 as amended, subject to the condition that not more than 30% of said gift shall be used by the donee for administration purposes. Very truly yours, (SGD.) ROMULO M. VILLA Acting Commissioner Bureau of Internal Revenue