Freedom in Christ Ministries, Inc.

March 5, 2009 BIR RULING [NSNP-(S30E-031) 188-09] Section 30 (E);S-30-027-2003 Freedom in Christ Ministries, Inc. Blk. 46 Lot 3 United Bayanihan, San Pedro Laguna Attention: Rev. Serlina Rufin Chairman Gentlemen : This refers to your letter dated November 10, 2008 which was received by this Office by way of 2nd Indorsement dated December 8, 2008 by the Revenue Region No. 9, San Pablo City for a tax exemption under Section 30 (E) of the Tax Code of 1997. It is represented that the Freedom in Christ Ministries, Inc. with TIN 220-449-714-000 is a non-stock, non-profit religious organization registered with the Securities and Exchange Commission under Registration No. 162745 dated April 7, 2006; that the aims and objectives for which the corporation is organized, are among others as follows, viz. : 1. The purpose of the Ministry is for the administration of its affairs, properties and temporalties. This non-stock corporation will not operate for the benefit of its board members but for the welfare of the needy and lost souls as well as disabled citizens of the communities. We will also support Christian missionaries who go forth to share the Gospel of the Lord Jesus Christ. Based on the foregoing, this Office is of the opinion and so holds that the Freedom in Christ Ministries, Inc. falls within the purview of a non-stock, non-profit organization as contemplated under Section 30 (E) of the Tax Code of 1997. Accordingly, it is exempt from the payment of income tax on income received by it as such organization, and therefore, need not file an income tax return. EHSIcT However, it is subject to the corresponding internal revenue taxes imposed under the National Internal Revenue Code of 1997 on its income derived from any of its properties, real or personal, or any activity conducted for profit regardless of the disposition thereof, which income should be returned for taxation. Likewise, interest income from currency bank deposits and yield or any other monetary benefit from deposit substitute instruments and from trust funds and similar arrangements, and royalties derived from sources within the Philippines are subject to the 20% final withholding tax; provided, however, that interest income derived from it from a depository bank under the expanded foreign currency deposit system shall be subject to 7 1/2% final withholding tax pursuant to Section 27 (D) (1) in relation to Section 57 (A),both of the Tax Code of 1997. Moreover, it is required to file on or before April 15 of each year a profit and loss statement and balance sheet with the annual information return under oath, stating its gross income and expenses incurred during the year and a certificate showing that there has not been any change in its By-Laws, Articles of Incorporation, manner of operation and activities as well as resources and disposition of income. It should be understood that the said exempt non-stock, non-profit religious organization shall be constituted as withholding agent for the government if it acts as an employer and its employees receive compensation income subject to the withholding tax under Section 79 (A), Chapter XIII, Title II of the Tax Code of 1997, as implemented by Revenue Regulations No. 2-98, or if it makes income payments to individuals or corporations subject to the withholding tax pursuant to Section 57 of the Tax Code of 1997, also as implemented by Revenue Regulations No. 2-98. It is of course understood that your books of accounts and other pertinent records shall be subject to periodic examination by revenue enforcement officers of this Bureau for the purposes of ascertaining whether you have been complying with the conditions under which you have been granted tax exemption or tax incentives and your tax liabilities, if any, pursuant to Section 235 of the Tax Code of 1997. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service