Donation of a Parcel of Land to a Non-stock Non-profit Charitable Corporation is Exempt from Donor's Tax

July 29, 1987 BIR RULING NO. 220-87 104 198-86 220-87 S i r : This refers to your letter dated September 23, 1986 requesting exemption from the donor's tax of the donation of a parcel of land situated in Paraaque, Metro Manila covered by TCT 47769 issued by the Registry of Deeds of Pasay City made in the favor of your client, the S of G Foundation, Inc. In reply, I have the honor to inform you that since the S of G Foundation, Inc. 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 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. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner