Donations to Foreign Missionaries Not Taxable

April 28, 1993 BIR RULING NO. 149-93 DONATIONS TO FOREIGN MISSIONARIES NOT TAXABLE 21 (c) 251-92 149-93 Quasha, Asperilla, Ancheta, Pea & Nolasco Lawyers Don Pablo Building, 114 Amorsolo St. Makati, Metro Manila Attention: Atty . Dennis G . Dimagiba This refers to your letter dated January 14, 1993 requesting for a ruling in behalf of your client, Foreign Mission Board, SBC-Philippine Baptist Mission (or FMB for brevity) that donations received by the foreign missionaries of Foreign Mission Board, are not subject to tax. It is represented that FMB is a non-stock, non-profit religious organization organized and existing under the laws of the State of Virginia, U.S.A.; that no part of the income inures to the benefit of any private shareholder or individual; that it is a missionary organization whose purpose is to send out missionaries to as many countries of the world as possible for the purpose of proclaiming the truth found in God's word the Bible; that FMB's missionaries in the Philippines and elsewhere, derive financial support from donations made by individuals and institutions in the United States of America; that these donations are specifically given to the individual missionaries where the designated missionaries are located and that the donated funds and channeled through FMB, which in return remits these funds through their respective missions. In reply, please be informed that since the financial support being received by the foreign missionaries are not compensation and/or salary but donations given them prior to their coming to the country, and that the funds are merely coursed through FMB for the account of the foreign missionaries, said financial support are not therefore, subject to Philippine income tax. It should be understood however, that if upon investigation, the facts are represented are found to be different, this ruling shall be null and void. VICTOR A. DEOFERIO, JR. Deputy Commissioner of Internal Revenue