Proceeds from the Presentation of a Musical Concert by a Non-stock Non-profit Corporation are Exempt from Payment of Taxes

November 6, 1991 BIR RULING NO. 232-91 Sec. 29 (h) (2) (c); 94 178-91 193-91 232-91 Gentlemen : This refers to your letter dated August 30, 1991 requesting, in behalf of your client, Hope Christian Alumni Welfare Foundation, Inc., for confirmation that the proceeds to be derived from its presentation of a musical concert are exempt from payment of taxes. It is represented that Hope Christian Alumni Welfare Foundation, Inc. is a non-stock, non-profit corporation duly registered with the Securities and Exchange Commission under Reg. No. 170195 on October 31, 1989; that it is a Qualified Donee Institution registered with the BIR under Certificate of Registration No. 1241; that among the purposes for which the foundation is formed are to provide an institutional framework or entity to initiate, pursue, develop, promote and achieve the ideals and mission of Hope Christian High School (Manila) in the rearing and education of the youth in the Christian faith, and initiating programs for welfare of the school alumni, faculty and studentry and to associate and work in cooperation with other groups and associations functioning with purposes kindred to those of the foundation; that as a foundation for non-profitable purposes it subsists on donations from local or foreign sources; that to pursue its purpose, the foundation will launch a campaign to raise funds by presenting a musical concert entitled "Love of Alumni" on October 25, 1991, 7:30 PM at the Philippine International Convention Center, the proceeds of which will fund the Foundation's scholarship and faculty welfare programs; and that no part of the funds of the foundation shall inure to the benefit of any individual or member. In reply, please be informed that the proceeds to be derived by the foundation from the holding of the musical concert "Love of Alumni" are exempt from income and business taxes. Such income, however, should be declared in the annual information return to be filed by the Foundation, the qualification of which as a tax-exempt organization should first be determined by this Office in accordance with Section 26 of the Tax Code as amplified by Revenue Regulations No. 2, otherwise known as the Income Tax Regulations, as amended. Very truly yours, (SGD.) JOSE U. ONG Commissioner