Donations of Real Properties
BIR Ruling No. 123-90 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jun 25, 1990
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June 25, 1990 BIR RULING NO. 123-90 94 490-88 123-90 Gentlemen : This refers to your letter dated June 18, 1990 requesting a ruling to the effect that the donations of real properties made by Messrs. Mercedes S. Florendo, Estrella Macaraeg Quilendrino, Josefina Florendo-Macaraeg and Raymundo Macaraeg in favor of The Sister Superior of the Holy Face of Jesus Sisters of Perpetual Adoration, Inc. are exempt from donor's tax. aisadc 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 donations are exempt from the payment of donor's gift tax pursuant to Section 94 of the Tax Code, as amended. However, the exemption from donor's tax is subject to the condition that not more than 30% of the said gifts shall be used by the donee for administration purposes. cdta Very truly yours, (SGD.) JOSE U. ONG Commissioner
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