BIR Ruling No. 120-83

June 29, 1983 BIR RULING NO. 120-83 Gentlemen : This refers to your letter dated May 6, 1983 requesting exemption from the donor's tax of donations made in favor of the Asilo de la Milagrosa. In reply, I have the honor to inform you that since the donee is a non-profit and non-stock charitable corporation, paying no dividends, governed by trustees who receive no compensation, and devoting all its income, whether student's fees, or gifts, donations, subsidies or other forms of philanthropy, to the accomplishment and promotion of the purposes enumerated in its 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 the donee for administration purposes. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue