Exemption from the Payment of Donor's Tax
BIR Ruling No. 397-88 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Aug 17, 1988
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August 17, 1988 BIR RULING NO. 397-88 94 (3) 130-88 397-88 Gentlemen : This refers to your letter dated December 15, 1987 requesting exemption from the payment of donor's tax of your donation of six (6) parcels of land situated at Bo. Halang, Juana Complex, Bian, Laguna, covered by Transfer Certificate of Title Nos. 128302, 128303, 128304, 128306, 128307 and 128308 in favor of Collegio San Agustin, Bian, Inc. by virtue of a Deed of Donation executed on November 20, 1987. It appears that the Colegio San Agustin, Bian, Inc. is a non-stock, non-profit educational corporation, paying no dividends, governed by trustees who received no compensation and devoting all its income, whether student's fees, or gifts, donations, subsidies or other forms of philanthropy, to the accomplishment and promotion of the purposes enumerated in its Articles of Incorporation. In reply, please be informed that the aforementioned donation is exempt from the payment of donor's tax pursuant to then Section 104(a)(3) [now Section (a) 94(3)] of the Tax Code, subject to the condition that not more than 30% of said gift shall be used by the donee for administration purposes. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner
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