Donations to the Parole and Probation Administration

August 9, 1990 BIR RULING NO. 145-90 94 (a) (2) & (b) (1) 000-00 145-90 Gentlemen : This refers to your letter dated February 19, 1990, in effect, requesting a ruling as to whether donations to the Parole and Probation Administration is exempt from donor's tax. cdt It is represented that the Parole and Probation Administration, a branch of service under the Department of Justice, promotes the rehabilitation of first-time offenders on probation and parolees/pardonees by providing them with individualized treatment in a community-based setting; that through the Community Services Division, it has drawn up a number of projects and is developing community-oriented programs aimed at increasing opportunities for the rehabilitation and reintegration of the probationers/parolees/pardonees into society; and that it utilizes the support of resource agencies in the community in carrying out its programs/services through availment of assistance in whatever form from the willing donors. In reply, please be informed that pursuant to Section 94 (a)(2) and (b)(1) of the Tax Code, as amended, gifts made by a resident or non-resident not a citizen of the Philippines to or for the use of the National Government or any entity created by any of its agencies which is not conducted for profit, or to any political subdivision of the said Government, shall be exempt from the donor's tax. Such being the case, since the donee, Parole and Probation Administration, is a government entity within the contemplation of Section 94 (a)(2) & (b)(1) of the Tax Code, then donations to it are exempt from the donor's tax. Very truly yours, (SGD.) JOSE U. ONG Commissioner