BIR Ruling No. 136-83

July 22, 1983 BIR RULING NO. 136-83 Gentlemen : This refers to your letter dated June 30, 1983 requesting exemption from the donor's tax of the donation of five (5) parcels of land all situated at Palante, Paraaque, Metro Manila covered by TCT Nos. 23045-A, 22080-A, 31042-A, 31041-A, and 347319 all of the Registry of Deeds of Rizal, made by spouses Eugenio B. Diaz and Teresita L. Diaz in favor of Saint Rita College, A.R. Paraaque, Inc. In reply thereto, I have the honor to inform you that since the donee is a non-profit and non-stock educational institution, 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. aisadc Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue