Donation of Parcel of Land to Andrew Gotianun Foundation, Inc. Exempt from Donor's Tax

September 29, 1986 BIR RULING NO. 198-86 104 118-85 198-86 Gentlemen : This refers to your letter dated July 1, 1980 requesting exemption from the donor's tax of the donation of a parcel of land situated in Marikina, Metro Manila, covered by Transfer Certificate of Title No. N-17092 of the Registry of Deeds for the province of Rizal made by you in favor of the Andrew Gotianun Foundation, Inc. In reply, I have the honor to inform you that since the donee is a non-profit and non-stock charitable corporation, paying no dividends, governed by trustees who receive 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, the aforementioned donation is exempt from the payment of donor's tax, pursuant to Section 104 of the Tax Code, as amended, provided that not more than thirty per centum (30%) of said gift shall be used by the donee for administration purposes. cdta Very truly yours, (SGD.) ROMULO M. VILLA Acting Commissioner