BIR Ruling No. 149-84
BIR Ruling No. 149-84 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Sep 5, 1984
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September 5, 1984 BIR RULING NO. 149-84 123 (a) (3); 30 (h)-106-84-149-84 Gentlemen : This refers to your letter dated August 14, 1984 requesting that donations made in your favor be exempt from donor's tax and the same be deductible from gross income of the donors. In reply, please be informed that the documentary evidence submitted show that you are an organization duly registered with the Securities and Exchange Commission and that you are organized exclusively for religious purposes. Accordingly, donations and/or contributions made in your favor are exempt from the payment of donor's tax pursuant to Section 123(a)(3) of the Tax Code, as amended. In this Connection, while you may be undertaking charitable activities such undertakings are merely incidental to the purpose for which you were organized which is religious. (BIR Ruling No. 01-75) In other words, you still remain a religious organization despite your charitable activities; hence donations or contributions to you are deductible from gross income of the donor or contributor, not in full, but subject to the 6% or 3% limitations, in accordance with Section 30(h)(l) of the Tax Code. This revokes the Certificate of Registration No. 0101 dated June 10, 1983 allowing full deduction of the donations or contributions to you from the gross income of the donor or contributor, for income tax purposes. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner
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