Tax Exemption of Donations Received by the Foreign Missionaries of Overseas Missionary Fellowship, Inc.

November 18, 1992 BIR RULING NO. 330-92 21 48-91 330-92 Overseas Missionary Fellowship, Inc. 900 Don Mariano Marcos Avenue Diliman, Quezon City Attention: Mr . Martin J . Rutty Area Secretary Gentlemen : This refers to your letter dated May 15, 1991 requesting for a ruling that donations received by the foreign missionaries of Overseas Missionary Fellowship, Inc. (formerly China Inland Mission, Inc.) are not subject to tax. It is represented that the Overseas Missionary Fellowship, Inc. (OMF) is a non-stock, non-profit corporation organized and existing under the State of Pennsylvania, U.S.A., and duly registered with the Securities & Exchange Commission; that it is a tax-exempt organization pursuant to Section 26 of the Tax Code, as amended, that it has foreign missionaries assigned and operating in the Philippines; that these missionaries do not receive compensation from the Philippines; that they derive financial support from funds in the form of cash, checks or pledges from friends and christian churches abroad prior to their departure to the Philippines; and finally, that these funds are coursed through the OMF-USA and then remitted to OMF Philippines and credited to the account of the foreign missionaries concerned. In reply, please be informed that since the financial support being received by the foreign missionaries are not compensation and/or salary but donations given them prior to their coming to the country, and that the funds are merely coursed through OMF for the account of foreign missionaries, said financial support are not therefore, subject to Philippine income tax. It should be understood, however, that if upon investigation, the facts as represented are found to be different, this ruling shall be null and void. Very truly yours, JOSE U. ONG Commissioner of Internal Revenue