Request for Exemption from Donor's Tax on Donation of a Parcel of Land to the Roman Catholic Archbishop of Manila

November 10, 1986 BIR RULING NO. 239-86 104 081-86 039-86 Gentlemen : This refers to your letter dated June 26, 1986 requesting exemption from the payment of donor's tax on the donation of a parcel of land located in Paco, Manila covered by Transfer Certificate of Title No. 41672 made by Mrs. Concepcion Andrea Gonzalez y Narciso in favor of your client, the Roman Catholic Archbishop of Manila, by virtue of a Deed of Donation executed on November 28, 1984. It appears that the Roman Catholic Archbishop of Manila is a religious corporation sole duly organized and existing under the laws of the Philippines. In reply, please be informed that inasmuch as the donee is a religious corporation, the aforementioned donation is exempt from the payment of donor's tax pursuant to Section 104 of the Tax Code as amended subject to the condition that not more than 30% of said gift shall be used by the donee for administration purposes. cdt Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner of Internal Revenue