Request for Exemption from Donor's Tax of the Donation in Favor of the Jesus Is Lord Christian School Foundation, Inc.

June 18, 1992 BIR RULING NO. 186-92 94 (a) (3) 148-90 186-92 Ms. Normandrea Carlos Gutierrez 68 Mendoza St. Baler, Quezon City M a d a m : This refers to your letter dated April 14, 1992 requesting exemption from the donor's tax of the donation you executed in favor of the Jesus Is Lord Christian School Foundation, Inc. consisting of a parcel of land covered by TCT No. F-206258 and situated in San Pedro, Laguna. Investigation conducted by this Office disclosed that the Jesus Is Lord Christian School is a non-stock, non-profit educational institution, paying no dividends, governed by trustees who received no compensation and devoting all its income whether student's fees or gifts, donations, subsidies or other forms of philanthropy, to the accomplishment and promotion of the purposes enumerated in its Articles of Incorporation. In reply, please be informed that gifts made in favor of a non-stock, non-profit educational institution within the contemplation of Section 24(a) (3) of the Tax Code, as amended, are exempt from the donor's tax provided that not more than thirty per centum of said gifts shall be used by such donee for administration purposes. Considering that Jesus Is Lord Christian Foundation, Inc. is a non-stock, non-profit educational institution, the aforementioned donation is exempt from the payment of donor's tax. aisadc Very truly yours, EUFRACIO D. SANTOS Deputy Commissioner