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1. a. Under the law, the responsibility of assuming the burden of paying the tax is on
the donor. Therefore, as between Manuela and Rafaela, the burden of paying
the tax is on the former.
b. Donor's tax returns should be filed within 30 days after the gift was made.
Since the donation was made February 20, 2001, the last day for filing the
donor's tax return is on March 22, 2001.
c. No. There is no extension for filing the return and payment of donor's taxes.

2. Yes, because the donor's tax was not paid. Before a title to a registrable property is
transferred in the name of the donee, the corresponding donor's tax on the transfer
should first be paid. Without paying the tax, the title will not be transferred to the
donee. It shall remain in the name of the donor.

3. a. The gifts in 2008 and 2009 are valued at P10,000,000 which is half of the
market value of the land (P20,000,000) donated. The basis in valuing the
property donated is the fair market value.
b. The Revenue District Officer is not correct. Since they were made in a different
year, the donations cannot be treated as one.