Tax Exemption Granted to the Institucion Teresiana De Educacion Y Cultura, Inc.

April 20, 1960 BIR RULING NO. 274-60 Miss Maria Pilar Sarasqueta President, Institucion Teresiana De Education Y Cultura, Inc. 1560 Dapitan, Manila M a d a m : Reference is made to your letter dated April 9, 1960, requesting for an exemption of the Institucion Teresiana De Educacion Y Cultura, Inc., in respect to income received by it. It appears from the "Affidavit and Articles of Incorporation" of the above-named corporation that it is a religious, educational, charitable and non-profit corporation. The purpose for which the corporation was organized "es dedicarse a la educacion e instruccion de ninos y jovenes de ambos sexes, conjunta or separadamente en todos sus grados y formas". (Par. 2, Articles of Incorporation). The income of the corporation comes from charitable contributions, salaries of some of its members teaching in other Catholic Schools and colleges and the dormitory at 1569 Dapitan. The corporation depends on charity of benevolent donors and on credit in order to pursue its lofty ideals and purposes. All of its income goes to its educational activities and no part of its income thereof, inures or may inure to the benefit of any private individual. Taking the facts as stated in the papers submitted, I have the honor to inform you that the corporation as a religious, charitable and educational institution, no part of the net income of which inures to the benefit of any private individual, is exempt from the income tax. However, the income from its properties, real or personal, or from any activity conducted for profit, regardless of the disposition of such income, is subject to income tax. lexlib Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue