BIR Ruling No. 178-83

October 11, 1983 BIR RULING NO. 178-83 S i r : This refers to your letter dated July 5, 1983 requesting exemption from the payment of donor's gift tax of the donation of a parcel of land covered by Transfer Certificate of Title No. 276686 of the Registry of Deeds of Pasay City, made by the Moonwalk Development and Housing Corporation, in favor of the Roman Catholic Archbishop of Manila. It appears that the donee is a religious corporation duly organized and existing under the laws of the Philippines. In reply, I have the honor to inform you that since the donee is a religious corporation, the aforementioned donation is exempt from the payment of donor's gift tax pursuant to Section 123(a)(3) of the Tax Code of 1977, as amended. However, the exemption from the donor's gift tax is subject to the condition that not more than 30% of the said gifts shall be used by the donee for administrative purposes. cdtech Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue