Tax Exemption of Gifts Made in Favor of a Non-Stock, Non-Profit Charitable Corporation

September 8, 1992 BIR RULING NO. 252-92 94 (a) (2) (b) (3) 076-92 252-92 Office of Protocol Department of Foreign Affairs Manila Attention: Mr . George B . Reyes Acting Director-General Gentlemen : This refers to the letter of the Embassy of the United States of America stating that the International Catholic Migration Commission (ICMC), a non-profit international organization which is an affiliate agency of the U.S. Mission under the Refugee Program, has donated a government-owned motor vehicle, a 1980 Ford Fiera utility vehicle with Serial/Engine No. 717089, to the Philippine Refugee Processing (PRPC), a non-stock, non-profit corporation operated for charitable purposes as contemplated under Section 26(e) of the Tax Code, as amended, pursuant to a Deed of Donation executed by and between ICMC and PRPC on August 29, 1991. It appears that the motor vehicle was purchased by ICMC under the US Refugee Program and is now without commercial value. In reply, please be informed that gifts made in favor of a non-stock, non-profit charitable corporation within the contemplation of Section 94(a)(3) and (b)(2) of the Tax Code is exempt from donor's gift tax. Such being the case, the donation by the International Catholic Migration Commission of the aforementioned vehicle is exempt from donor's tax. This will serve as the authority for the Philippine Refugee Processing Center to transfer the registration certificate of the said motor vehicle in its name. cdtech Very truly yours, JOSE U. ONG Commissioner of Internal Revenue