Request for Exemption from Gift Tax on Donation of Parcel of Land to the Roman Catholic Archbishop of Manila

September 16, 1986 BIR RULING NO. 171-86 104-(a) (3) 113-85 171-86 Gentlemen : This refers to your letter dated June 28, 1986 requesting exemption from the payment of donor's gift tax on the donation by Mrs. Lucia Manotoc-Macam of one (1) parcel of land covered by Transfer Certificate of Title No. 1165333 of the Register of Deeds of Caloocan, in favor of the Roman Catholic Archbishop of Manila. It appears that the donee is a religious corporation sole. In reply, I have the honor to inform you that since the donee is a religious corporation sole, the aforementioned donation is exempt from the payment of donor's gift tax pursuant to Section 104(a)(3) of the Tax Code, as amended. However, the exemption from the donor's tax is subject to the condition that not more than 30% of the said gift shall be used by the donee for administration purposes. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner