Tax Census Statement Filed by Resident Religious Corporations and Bishops, Priest and Ministers

December 3, 1958 BIR RULING NO. 700-58 M/Rev. Ruperto F. Villoria Sinapawan, Sta. Fe Nueva Vizcaya S i r : In reply to your letter of October 15, 1958, I have the honor to inform you that resident religious corporations and bishops, priest and ministers thereof are required to file the tax census statement prescribed by Republic Act No. 2070. cdll Property of itself is not subject to income tax; however, the income received from such property is subject to income tax. For purposes of your query, there is quoted below Section 27(e) of the National Internal Revenue Code: "SEC. 27. Exemptions from tax on corporation . The following organizations shall not be taxed under this Title in respect to income received by them as such . . . (e) Corporation or association organized and operated exclusively for religious, charitable, scientific, athletic, cultural, or educational purposes, or for the rehabilitation of veterans no part of the net income of which inures to the benefit of any private stockholder or individual: Provided, however, That the income of whatever kind and character from any of its properties, real or personal , or from any activity conducted for profit, regardless of the disposition made of such income, shall be liable to the tax imposed under this income, shall be liable to the tax imposed under this Code ; (Emphasis supplied) Donations from local sources to the religious corporations and to members thereof are subject to the gift taxes prescribed in Sections 109 and 110 of the Tax Code. Donations, however, from abroad to religious institutions are exempt from all taxes, pursuant to Republic Act No. 1916. llcd Respectfully yours, (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue