BIR Ruling No. 165-84

October 4, 1984 BIR RULING NO. 165-84 34-067-80-165-84 Gentlemen : This refers to your letter dated November 22, 1982 requesting a ruling to the effect that the gain derived by the Philippine Crusades, Inc. from the sale of its real properties situated at New Saniga, Mandaluyong, Rizal, is not subject to tax. It is represented that the Philippine Crusades, Inc. is a religious corporation organized and existing under the laws of the Philippines; that on July 20 and September 8, 1982 it sold its properties situated at New Saniga, Mandaluyong, Metro Manila covered by Transfer Certificates of Titles Nos. 478377-Rizal, 458378-Rizal, 458379-Rizal and 458380-Rizal to Messrs. Neptali A. Gonzales and Elionor Pillas; that the corporation on November 18, 1982, purchased two parcels of land situated at Nos. 41 and 37 Cordillera St., Mandaluyong, Metro Manila, covered by Transfer Certificates of Title Nos. 458212 and 458211 of the Registry of Deeds of Rizal, out of the proceeds of the aforesaid sale to be used as the permanent office of the corporation. In reply thereto, please be informed that while a corporation or association organized and operated exclusively for religious, charitable, scientific, athletic, or cultural purposes, or for the rehabilitation of veterans, no part of the net income of which inures to the benefit of any private stockholder or individual, is exempt from tax on income received by them as such, nevertheless, the income of whatever kind and character of the organization from any of its properties, real or personal , or from any of its activities conducted for profit regardless of the disposition made of such income shall be subject to tax pursuant to Section 27 of the Tax Code, as amended. Such being the case, the gain derived from your sale of the aforesaid real properties is subject to the ordinary corporate income tax imposed under Section 24(a) of the Tax Code, as amended. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner