Allowances Given to Ford Foundation Grantees

September 14, 1959 BIR RULING NO. 464-59 Mr. Canute Vander Meer 953-A C. Padilla St., Mambaling Cebu City S i r : This is in connection with your letter dated February 24, 1959. It appears from your said letter that you are an American citizen registered under A.C.R. No. B-26305 dated September 24, 1958; that you came to the Philippines as "temporary visitor" in connection with a fellowship granted you by the Ford Foundation, a non-profit or philanthropic organization; that as such fellowship grantee, you are undertaking a one-year study, which begun on August 1, 1958, of the agricultural land use in the Philippines; that to support your studies and research, you are given by the Ford Foundation an allowance in the total amount of $7,400, as follows: (a) $3,600 to pay for the cost of housing and food while in the Philippines; (b) $2,800 for two round-trip air travel between the United States and the Philippines; (c) $500 for transportation expenses in the Philippines; and (d) $500 for research expenses. Your query is whether or not the foregoing allowances are taxable income in the Philippines. In reply thereto, I have the honor to inform you that, under the foregoing facts, the aforesaid allowances cannot be considered as income earned by you during your stay in the Philippines, much less as income from sources within the Philippines, and, therefore, are not subject to Philippine income tax. cdta Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue