Exemption from the Payment of Donor's Gift Tax

September 17, 1990 BIR RULING NO. 180-90 94 (a) (3) 138-90 180-90 Gentlemen : This refers to your letter dated July 31, 1990 requesting in behalf of your client, The Superior General of the Religious of the Virgin Mary, a ruling confirming your opinion that the donation by Madre Maria Sousa, R.V.M. of a parcel of land situated at La Trinidad, Benguet Province and covered by TCT No. T-21584 made in favor of your abovenamed client is exempt from donor's tax pursuant to Section 94 of the Tax Code, as amended. aisadc It appears that the donee is a religious corporation duly authorized 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 94(a)(3) of the Tax Code, as amended. However, the exemption from 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.) JOSE U. ONG Commissioner