Gift Distribution Program Proposal of CARE

September 29, 1959 BIR RULING NO. 481-59 Respectfully returned to the Honorable, the Secretary of Finance, Manila. It appears that the Cooperative for American Relief Everywhere, Inc. (CARE), a non-profit, private organization made up of 26 American relief, religious, labor, civic and cooperative agencies, has proposed to the Philippine Government a gift distribution program by offering to extend direct assistance in the form of relief, rehabilitation and reconstruction equipment and material and other urgently needed commodities to individuals and lawfully existing organizations in the Philippines designated by or on behalf of the donors. Under the proposed agreement, the Philippine Government will admit into this country free of tax the commodities, equipment and supplies required to be imported by CARE for the administration of the program, the personal effects, equipment and supplies of American employees of CARE and commodities intended for the Philippines imported by CARE. Furthermore, the Philippine Government will not levy taxes on CARE, its assets, properties, receipts, operations, or the salaries, per diems or other remuneration for personal services paid by CARE to its personnel of non-Filipino nationality. Considering the fact that the aforesaid commodities will be donated by CARE to be distributed by way of relief and rehabilitation to individuals and lawfully existing organizations in the Philippines designated by or on behalf of the donors, this Office offers no objection to the exemption of the aforesaid commodities, as well as the articles mentioned above, from the corresponding internal revenue tax. This Office likewise interposes no objection to the exemption from income tax on salaries and other compensation paid by CARE to its personnel of non-Filipino nationality. (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue