BIR Ruling No. 412-61

October 16, 1961 BIR RULING NO. 412-61 Mr. Edgardo V. Guevarra 120 K-3 Street, Kamuning Quezon City S i r : Reference is made to your query dated January 18, 1961 regarding the conditions that should be complied with by foundations organized for scientific advancement in order to avail of the tax exemption provided in Section 24 of Republic Act 2067. The pertinent provision of Republic Act 2067 reads as follows: "SEC. 24. . . .. All funds contributed to the support and maintenance of such foundations and their projects as well as specific research and development projects undertaken by private individuals and educational institutions, shall be tax-exempt and deductible from the donor's income tax returns, upon certification by the Board that such foundations and funds are dedicated to scientific pursuits." A foundation created for scientific advancement is exempt from tax under the abovequoted provision of law if the foundation as well as the funds contributed for its support and maintenance are dedicated exclusively for scientific pursuits. A certification to this effect issued by the Board is required under the law. In addition the foundation should keep a record of all the contributions and donations received by it as well as all dispositions made from such funds. These records must be made available to our investigating agents who may be authorized to verify the same. In this connection, please be informed that a foundation is not organized exclusively for scientific purposes unless upon dissolution its assets would, by reason of its charter or by operation of law, be distributed to similar exempt organizations or to the Government. aisadc Very truly yours, (SGD.) MELECIO DOMINGO Commissioner of Internal Revenue