Request for Tax Exemption on Donation of Parcels of Land to the Provincial Superior of Canossian Daughters of Charity

July 29, 1985 BIR RULING NO. 113-85 123-a-3 232-83 113-85 Gentlemen : This refers to your letter dated June 17, 1985 requesting exemption from the payment of donor's gift tax on the donation of six (6) parcels of land covered by Transfer Certificates of Title Nos. 85332, 85333 and 85335 of the Register of Deeds of Calamba, Laguna: Transfer Certificates of Title Nos. 18668 and 18669 of the Register of Deeds of San Pablo City; and, Transfer Certificate of Title No. 49474 of the Register of Deeds of Lipa City made by the Mater Dei Canossian Academy, Inc., Calamba, Laguna, Our Lady of Fatima Academy, Inc., Lakeside Park, San Pablo City and Canossa Academy of Lipa City respectively in favor of the Provincial Superior of the Canossian Daughters of Charity Phils., Inc. It appears that the donee is a religious corporation duly organized and existing under the laws of the Philippines. In reply, I have the honor to inform you that since 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, as amended. However, the exemption from the donor's tax is subject to the condition that not more than 30% of the said gifts shall be used by the donee for administrative purposes. cdta Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner