BIR Ruling No. 193-82

June 9, 1982 BIR RULING NO. 193-82 021 00-000 193-82 Philippine Band of Mercy 22 East Avenue Quezon City Attention: Mr . Elmer Estrella Executive Director Gentlemen : In reply to your letter dated February 24, 1982, I have the honor to inform you that pursuant to Batas Pambansa Bilang 135 donations to a private foundation which is a qualified donee institution under the BIR-NEDA Regulations No. 1-81 are no longer deductible by individuals receiving purely compensation income. The individual employee's taxable compensation income shall be determined by subtracting from his gross compensation income only personal and additional exemptions to which he is entitled. However, in the case of corporations and individuals receiving business income, income from profession, trade or vocation, their donations or contributions to your organization shall remain deductible subject to the conditions set forth in Section 3 of said BIR-NEDA Regulations, implementing paragraph (h) of Section 30 of the Tax Code as amended by Batas Pambansa Bilang 45. (See Revenue Memorandum Circular No. 5-82 dated January 21, 1982) As a charitable organization, you are subject to the 15% final tax on interest income of your savings deposits and 20% in the case of time deposits and yield from deposit substitutes pursuant to Section 24(cc) of the Tax Code, as amended by Presidential Decree No. 1739. aisadc Very truly yours, RUBEN B. ANCHETA Acting Commissioner