Request for Exemption from Donor's Tax of the Donation of a Parcel of Land to the John Ver Gonzales Foundation

August 6, 1985 BIR RULING NO. 118-85 123 (a) (3) 120-83 118-85 Gentlemen : This refers to your letter dated May 16, 1985 requesting exemption from the donor's tax of the donation of a parcel of land situated in Alfonso, Cavite and covered by TCT No. T-85708 of the Registry of Deeds for the province of Cavite made in your favor by the John Ver Gonzales Foundation for The Mentally Retarded Children, Inc. In reply, I have the honor to inform you that since you are a non-profit and non-stock charitable corporation, paying no dividends, governed by trustees who receive no compensation and devoting all your income, whether students' fees, or gifts, donations, subsidies or other forms of philanthropy, to the accomplishment and promotion of the purposes enumerated in your articles of incorporation, the aforementioned donation is exempt from the payment of donor's tax, pursuant to Section 123(a)(3) of the Tax Code, as amended, provided that not more than thirty per centum (30%) of said gift shall be used by you for administration purposes. aisadc Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner