BIR Ruling No. 140-82

April 23, 1982 BIR RULING NO. 140-82 123-a-3 079-00 140-82 I.C.M. Sisters Phil. Mission Board, Inc. ICM District House, 61 Banawe St. Quezon City Attention: Sister Modesta Suico, ICM President Gentlemen : This refers to your letters all dated December 9, 1980 requesting exemption from the payment of donor's tax of the following donations: (1) Social Center Bldg. constructed on the lot belonging to the Missionary Sisters of the Immaculate Heart of Mary, Inc. along the National Road Bondoc-Tagudin, at Poblacion, Bauko, Mt. Province; (2) Four Hundred Thousand (P400,000.00) pesos cash; and (3) Three Hundred Forty One Thousand Six Hundred Sixty Six Pesos and Sixty Five centavos (P341,666.65) cash; made by you in favor of the Catholic Vicar Apostolic of the Mt. Province, Pag-asa Human Development Foundation, Inc. and Missionary Sisters of the Immaculate Heart of Mary, Inc. respectively, pursuant to Section 123(a)(3) of the National Internal Revenue Code of 1977, as amended. It appears that the Catholic Vicar Apostolic of the Mt. Province is a corporation sole organized for religious purposes; that the Pag-asa Human Development Foundation, Inc., is a non-stock, non-profit social welfare and charitable organization; and that the Missionary Sisters of the Immaculate Heart of Mary is a non-stock and non-profit corporation, organized and existing for religious mission work no part of the income of which inures to the benefit of any stockholder or individual. cdtech In reply thereto, I have the honor to inform you that as the donees are religious and social welfare organizations, donations made in their favor are exempt from the payment of donor's gift tax pursuant to Section 123(a)(3) of the National Internal Revenue Code of 1977, as amended subject to the condition that not more than 30% of said gifts are used for administration purposes. Very truly yours, RUBEN B. ANCHETA Acting Commissioner