BIR Ruling No. 232-83

December 16, 1983 BIR RULING NO. 232-83 Gentlemen : This refers to your letter dated October 17, 1983 requesting exemption from the payment of donor's gift tax of the donation of two (2) parcels of residential land covered by Transfer Certificates of Title Nos. 33240 and 62069 of the Registry of Deeds, Manila, made by the Philippine General Council of the Assemblies of God, Inc., U.S.A. in favor of the Manila Bethel Temple, Inc. It appears that the donee is a religious corporation duly organized 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 123(a)(3) of the Tax Code of 1977, as amended. However, the exemption from the donor's gift tax is subject to the condition that not more than 30% of the said gifts shall be used by the donee for administration purposes. cdti Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue