Application of RA No. 1916

November 19, 1958 BIR RULING NO. 685-58 The Philippine Federation of Christian Churches 1648 Taft Ave., Manila Gentlemen : With further reference to your letter dated July 12, 1957, requesting that the provisions of Republic Act No. 1916 be made to apply to radio station DYSR, Dumaguete City, I have the honor to inform you as follows: LibLex In the investigation conducted by this Office, it was found out that said radio station is being operated not only for religious purposes but also for educational and other purposes. This fact is borne out by the Program Schedule of that radio station covering the period from July to September, 1958, copies of which were furnished this Office thru our agent who actually conducted the investigation of this case. Moreover, we note that the franchise, in virtue of which station DYSR is being operated, had been granted in favor of the Silliman University, and educational institution, although that Federation was extended the privilege of sharing with said University the rights and privileges of the franchise, so much so that the purposes for which the franchise was granted are not limited to religious but covers educational and cultural purposes as well. (See R.A. No. 515, as amended by R.A. No. 2089). Accordingly, and considering that in order to enjoy the tax-exemption under Republic Act No. 1916, the donation in question must be used exclusively for religious purposes only, donations coming from abroad and consigned to the aforenamed radio station for its use are subject to the compensating tax prescribed in Section 190 of the National Internal Revenue Code. LLjur This supersedes our letters to you dated July 30 and September 6, 1957 Very truly yours, (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue