Donation to a Religious Organization - Exempt from Donor's Tax

November 19, 1993 BIR RULING NO. 452-93 DONATION TO A RELIGIOUS ORGANIZATION EXEMPT FROM DONOR'S TAX 94 (a) (3) 301-92 452-93 The Superior General of the Religious of the Virgin Mary, Inc. 214 N. Domingo St. Quezon City Attention: M . Maria Asumpta M . David, RVM This refers to your letter dated August 18, 1993, requesting exemption under Section 94(a)(3) of the Tax Code, as amended, of the donation made by Ms. Luciana Figueroa of two (2) parcels of land located in Lagao, General Santos City, containing an area of three hundred seventy-two (372) square meters and twenty-nine (29) square meters covered by Tax Declaration Nos. 20191 and 20188, respectively, in favor of The Superior General of the Religious of the Virgin Mary executed on August 31, 1990. Documents submitted show that The Superior General of the Religious of the Virgin Mary, Inc. is a religious corporation sole for the principal purpose of administering its temporalities. In reply, please be informed that inasmuch as the donee is a religious institution, the aforementioned donation is exempt from the payment of donor's tax pursuant to Section 94(a)(3) of the Tax Code, as amended, subject to the condition that not more than 30% of said gift shall be used by the donee for administration purposes. Moreover, the aforesaid Deed of Donation is not subject to the documentary stamp tax prescribed under Section 196 of the Tax Code, as amended, but only to the documentary stamp tax of P3.00 imposed under Section 188 of the same Code. aisadc LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue