Contribution of Real Properties of the Partners to the Registered General Partnership Fund is Not Subject to Income Tax
BIR Ruling No. 162-87 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jun 11, 1987
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June 11, 1987 BIR RULING NO. 162-87 20 (b) 000-00 162-87 S i r : This refers to your letter dated May 25, 1987 requesting a ruling on the tax consequence of the contribution of real properties of the partners to the registered general partnership fund. In reply, please be informed that contributions to the general partnership fund is a capital investment which is not included within the purview of the term "taxable income" as defined in Section 28, in relation to Section 29 of the Tax Code; hence, the partner's contribution of real properties to the partnership fund is not subject to income tax. This ruling shall serve as the authority for the Register of Deeds to register the aforesaid properties in the name of the registered general partnership. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner
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