Exemption from Donor's Tax

July 24, 1990 BIR RULING NO. 138-90 94 (a) (3) 123-90 138-90 Gentlemen : This refers to your letter dated May 28, 1990 requesting in behalf of your client, Dominican Daughters of the Immaculate Mother, Inc. a ruling confirming your opinion that the donation by Austrade Realty, Inc. of a parcel of land situated at Quezon City and covered by TCT No. 285762 made in favor of your abovenamed client is exempt from donor's tax pursuant to Section 94 of the Tax Code, as amended. aisadc It appears that the donee is a religious corporation duly authorized 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 94(a)(3) 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 gift shall be used by the donee for administration purposes. cdta Very truly yours, (SGD.) JOSE U. ONG Commissioner