BIR Ruling No. 178-11

May 27, 2011 BIR RULING NO. 178-11 Section 101 (A) (2) of the Tax Code of 1997, as amended; BIR Ruling [DA-(DT-063) 663-09]; DA-019-2001; DA-302-2003; DA-328-2008 The Heirs of Balbino A. Mangubat 2068 M. Mangubat Street, Interior Aurora Street, Pasay City Attention: Liwayway B. Mangubat Widow/Heir Gentlemen : This refers to your letter dated February 10, 2011 requesting for a ruling that the donation of the Heirs of Balbino A. Mangubat of a road lot covered by TCT No. 140367 and registered under the name of Balbino A. Mangubat, married to Liwayway Mangubat of the Registry of Deeds of Pasay City, in favor of the City Government of Pasay City, is exempt from donor's tax pursuant to Section 101 (A) (2) of the Tax Code, as amended. CITDES In reply, please be informed that under Section 101 (A) (2) of the Tax Code of 1997, as amended, gifts made to or for the use of the National Government or any entity created by any of its agencies which is not conducted for profit, or to any political subdivision of the said Government are exempt from donor's tax. Considering that the donation of the road lot covered by TCT No. 140367 of the Registry of Deeds of Pasay City was made by the Heirs of Balbino A. Mangubat in favor of the City Government of Pasay City, a political subdivision of the National Government, said donation, therefore, is exempt from donor's tax. (BIR Ruling Nos. DA-019-2001 dated February 15, 2001/DA-302-2003 dated September 16, 2003/DA-328-2008 dated May 30, 2008/and DA-(DT-063) 663-09 dated November 11, 2009) This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, (SGD.) KIM S. JACINTO-HENARES Commissioner of Internal Revenue