BIR Ruling [UN-015-94]

January 14, 1994 BIR RULING [UN-015-94] Pastor Brett M. Warren Manila Revival Faith Fellowship, Inc. 2nd Floor, Boy Scout of the Phils. Bldg. Quezon City High School Ybardolaza St., Kamuning Quezon City Dear Pastor Warren, This refers to your letter dated December 18, 1993 stating that you are the presiding minister of the Manila Revival Faith Fellowship, a Christian Fellowship; that it is a non-stock, non-profit religious organization duly registered with the Securities and Exchange Commission under S.E.C. Reg. No. 148465 dated February 15, 1988; that as a Christian Missionary here in the Philippines, all your personal as well as your family needs are supplied from funds coming from the parent church, Geelong Revival Centre, Ltd., Australia and not from local churches, that for the past three years, you have not obtained financial support from local sources; and that per Affidavit of Support executed by Pastor Noel Herbert Hollins, the said parent church guarantees the financial support of your ministry in the Philippines and the needs of your family in regard to housing, food, clothing and other expenses, which fund will be provided by bank transfer from the Revival Trust Account, State Bank, Geelong Victoria, Australia to an account controlled by you, i.e. Hongkong Bank at Pasig, Metro Manila, and now at the Bank of Philippines Islands, Kamias Branch, Quezon City; and finally, that the money sent from Australia is provided by the voluntary donations of the members of your Churches in Australia. In connection therewith you now request for a letter of tax exemption to enable you to get an extension of your missionary visa from the Bureau of Immigration. In reply, please be informed that if as represented you do not derive any personal income from the missionary work you do in the Philippines, except the remittances for your subsistence and maintenance from the parent church, Geelong Revival Centre, Ltd., Australia, you are not subject to income tax prescribed under Section 21 (a) of the Tax Code, as amended. Moreover, whatever financial support to be received by you from voluntary donations of members of your churches in Australia shall not be considered as taxable compensation under Section 28 of the Tax Code, as amended. cdtech Very truly yours, JAIME M. MAZA Assistant Commissioner (Legal Service)