Deductions-special-laws.docx

LIST OF ALLOWABLE DEDUCTIONS UNDER SPECIAL LAWS TABLE OF CONTENTS CONTENTS

1. Republic Act No. 6971 - Productivity Incentives Act of 1990 AN ACT TO ENCOURAGE PRODUCTIVITY AND MAINTAIN INDUSTRIAL PEACE BY PROVIDING INCENTIVES TO BOTH LABOR AND CAPITAL 2. Republic Act No. 8502 - Jewelry Industry Development Act of 1998 AN ACT TO PROMOTE THE DEVELOPMENT OF THE JEWELRY MANUFACTURING INDUSTRY, PROVIDING INCENTIVES THEREFOR AND FOR OTHER PURPOSES 3. Republic Act No. 7916 - the Special Economic Zone Act of 1995 Revenue Regulations (RR) 11-05 - Allowable deductions for PEZA registered enterprises 4. Republic Act No. 8525 - Adopt-a-School Act of 1998 N ACT ESTABLISHING AN "ADOPT-A-SCHOOL PROGRAM," PROVIDING INCENTIVES THEREFOR, AND FOR OTHER PURPOSES

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5. REVENUE REGULATIONS NO 7-2010 issued on July 20, 2010 implements the tax privileges provisions of RA 9994, otherwise known as the “Expanded Senior Citizen Act of 2010” 6. Republic Act No. 10028 - Expanded Breastfeeding Promotion Act of 2009 AN ACT EXPANDING THE PROMOTION OF BREASTFEEDING, AMENDING FOR THE PURPOSE REPUBLIC ACT NO. 7600, OTHERWISE KNOWN AS "AN ACT PROVIDING INCENTIVES TO ALL GOVERNMENT AND PRIVATE HEALTH INSTITUTIONS WITH ROOMING-IN AND BREASTFEEDING PRACTICES AND FOR OTHER PURPOSES" 7. Republic Act No. 9999 - Free Legal Assistance Act of 2010 AN ACT PROVIDING A MECHANISM FOR FREE LEGAL ASSISTANCE AND FOR OTHER PURPOSES 8. Republic Act No. 1855 AN ACT TO PLACE LIFE INSURANCE COMPANIES ON AN NEW INCOME TAX BASIS BY AMENDING SECTIONS TWENTY-FOUR AND THIRTY-TWO OF COMMONWEALTH ACT NUMBERED FOUR HUNDRED AND SIXTY-SIX, OTHERWISE KNOWN AS THE NATIONAL INTERNAL REVENUE CODE, AS AMENDED. 9. Republic Act No. 9442 AN ACT AMENDING REPUBLIC ACT NO. 7277, OTHERWISE KNOWN AS THE “MAGNA CARTA FOR DISABLED PERSONS, AND FOR OTHER PURPOSES 10. Republic Act No. 9400 AN ACT AMENDING REPUBLIC ACT NO. 7227, AS AMENDED, OTHERWISE KNOWN AS THE BASES CONVERSION AND DEVELOPMENT ACT OF 1992, AND FOR OTHER PURPOSES 11. Republic Act No. 10072 - Philippine Red Cross Act of 2009 2

AN ACT RECOGNIZING THE PHILIPPINE NATIONAL RED CROSS AS AN INDEPENDENT, AUTONOMOUS, NONGOVERNMENTAL ORGANIZATION AUXILIARY TO THE AUTHORITIES OF THE REPUBLIC OF THE PHILIPPINES IN THE HUMANITARIAN FIELD, TO BE KNOWN AS THE PHILIPPINE RED CROSS 12. REPUBLIC ACT 8292 - Higher Education Modernization Act of 1997 13. REPUBLIC ACT No. 10390 AN ACT AMENDING REPUBLIC ACT NO. 7306, ENTITLED "AN ACT PROVIDING FOR THE ESTABLISHMENT OF THE PEOPLE’S TELEVISION NETWORK, INCORPORATED, DEFINING ITS POWERS AND FUNCTIONS, PROVIDING FOR ITS SOURCES OF FUNDING AND FOR OTHER PURPOSES" 14. REPUBLIC ACT NO. 10174 AN ACT ESTABLISHING THE PEOPLE'S SURVIVAL FUND TO PROVIDE LONG-TERM FINANCE STREAMS TO ENABLE THE GOVERNMENT TO EFFECTIVELY ADDRESS THE PROBLEM OF CLIMATE CHANGE, AMENDING FOR THE PURPOSE REPUBLIC ACT NO. 9729, OTHERWISE KNOWN AS THE "CLIMATE CHANGE ACT OF 2009″, AND FOR OTHER PURPOSES

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LIST OF ALLOWABLE DEDUCTIONS UNDER SPECIAL LAWS

1. Republic Act 6971 - Productivity Incentives Act of 1990 Section 7. Benefits and Tax Incentives. - (a) Subject to the provisions of Section 6 hereof, a business enterprise which adopts a productivity incentives program, duly and mutually agreed upon by parties to the labor-management committee, shall be granted a special deduction from gross income equivalent to fifty percent (50%) of the total productivity bonuses given to employees under the program over and above the total allowable ordinary and necessary business deductions for said bonuses under the National Internal Revenue Code, as amended. b) Grants for manpower training and special studies given to rank-and-file employees pursuant to a program prepared by the labor-management committee for the development of skills identified as necessary by the appropriate government agencies shall also entitle the business enterprise to a special deduction from gross income equivalent to fifty per cent (50%) of the total grants over and above the allowable ordinary and necessary business deductions for said grants under the National Internal Revenue Code, as amended. c) Any strike or lockout arising from any violation of the productivity incentives program shall suspend the effectivity thereof pending settlement of such strike or lockout: Provided, That the business enterprise shall not be deemed to have forfeited any tax incentives accrued prior to the date of occurrence of such strike or lockout, and the workers shall not be required to reimburse the productivity bonuses already granted to them under the productivity incentives program. Likewise, bonuses which have already accrued before the strike or lockout shall be paid the workers within six (6) months from their accrual. 4

d) Bonuses provided for under the productivity incentives program shall be given to the employees not later than every six (6) months from the start of such program over and above existing bonuses granted by the business enterprise and by law: Provided, that the said bonuses shall not be deemed as salary increases due the employees and workers. e) The special deductions from gross income provided for herein shall be allowed starting the next taxable year after the effectivity of this Act. 2. Republic Act No. 8502 - Jewelry Industry Development Act of 1998 Section 3. Development incentives. – The following incentives shall be available to qualified jewelry enterprises in the jewelry industry: a) Entitlement to zero (0) duty on imported raw materials which include precious metals, loose gems, precious stones, jewelry parts, accessories and supplies for use by jewelry enterprise, as specifically mentioned in Chapter 5 of Sec. I, Chapter 12 of Sec. II, Chapters 25, 26 and 27 of Sec. V, Chapters 28, 34 and 38 of Sec. VI, Chapter 70 of Sec. XIII, Chapter 71 of Sec. XIV, Chapter 83 of Sec. XV, and Chapter 96 of Sec. XX of the Tariff and Customs Code, as amended; b) Exemption from the imposition of excise tax on all goods commonly or commercially known as jewelry, whether real or imitation pearls, precious and semi-precious stones and imitations thereof; all goods made of, or ornamented, mounted or fitted with precious metals or imitations thereof, as specifically mentioned in Sec. 150(a) of the National Internal Revenue Code of the Philippines, as amended; c) Entitlement to zero (0) duty on imported capital equipment, including spare parts and toolings thereof falling within Chapter 69 of Sec. XIII, Chapter 82 of Sec. XV, Chapters 84 and 85 of Sec. XVI, and Chapter 90 of Sec. XVIII of the Tariff and Customs Code, as amended; d) Additional deduction from taxable income of fifty percent (50%) of expenses incurred in training schemes approved by the appropriate agency and which shall be deductible during the financial year the expenses were incurred; e) Gold and silver sales by the Bangko Sentral ng Pilipinas to jewelry enterprises wider minimal margins; f) Authority for jewelry enterprises to buy gold and silver directly from other sources; g) Inclusion of locally-manufactured jewelry in the government's tourist duty free shops including the promotion, advertisement and sale thereof; and 5

h) Jewelry enterprises availing of incentives provided under this Act shall still be eligible to incentives provided by other special laws such as Republic Act No. 7844 (Export Development Act of 1994), Republic Act No. 7916 (Special Economic Zone Act of 1995), Executive Order 226 (BOI Omnibus Investments Code), among others: Provided, That the activity is export-oriented and that there is no double availment of the same incentives. 3. Revenue Regulations (RR) 11-05 - Allowable deductions for PEZA registered enterprises 

Direct salaries, wages or labor expenses

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Production supervision salaries

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Raw materials used in the manufacture of products

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Decrease in goods in process account (intermediate goods)

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Decrease in finished goods account

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Supplies and fuels used in production

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Depreciation of machineries and equipment used in the rendition of registered services; portion of the building owned or constructed used exclusively in the rendition of registered service

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Rent and utility charges for buildings and capital equipment used in the rendition of registered services

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Financing charges associated with fixed assets used in the registered service business the amounts of which were not previously capitalized.

Note: The CTA ruled in East Asia Utilities Corporation vs the Commissioner of Internal Revenue (CTA Case No. 8179), promulgated May 21, 2014 that the list of direct costs under RR 11-05 is not exclusive. The list serves only as a guide in determining what items may be considered as direct costs or cost of sales. That the criteria in determining whether or not the item of cost or expense should be part of the direct cost is the direct relation of the expense in the rendition of the PEZA-registered services. If the item of cost or expense can be directly attributed in providing the PEZA-registered services, then it should be treated as direct cost. In the abovementioned case, the costs of services such as employee benefits, technical training of employees were directly related to their registered activity, hence, CTA allowed these as deductions. 4. Republic Act No. 8525 - Adopt-a-School Act of 1998

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Section 5. Additional deduction for expenses incurred for the adoption. – Provisions of existing laws to the contrary notwithstanding, expenses incurred by the adopting entity for the "Adopt-A-School Program" shall be allowed an additional deduction from the gross income equivalent to fifty percent (50%) of such expenses. Valuation of assistance other than money shall be based on the acquisition cost of the property. Such valuation shall take into consideration the depreciated value of the property in case said property has already been used. 5. REVENUE REGULATIONS NO 7-2010 issued on July 20, 2010 implements the tax privileges provisions of RA 9994, otherwise known as the “Expanded Senior Citizen Act of 2010” Section 12. Additional Deduction from Gross Income of Private Establishment for Compensation Paid to Senior Citizens. - Private establishments employing Senior Citizens shall be entitled to additional deduction from their gross income equivalent to 15% of the total amount paid as salaries and wages to Senior Citizens subject to the provision of Section 34 of the Tax Code and its implementing rules and regulations provided the following conditions are met: A. The employment shall have to continue for a period of at least 6 months; B. The annual taxable income of the Senior Citizen does not exceed the poverty level as may be determined by the NEDA thru the NSCB. For this purpose, the Senior Citizen shall submit to his employer a sworn certificate that his annual income does not exceed the poverty level. 6. REPUBLIC ACT No. 10028 - Expanded Breastfeeding Promotion Act of 2009 Section 14. Section 13 of Republic Act No. 7600 is hereby renumbered and amended to read as follows: "Sec. 19. Incentives. - The expenses incurred by a private health and non-health facility, establishment or institution, in complying with the provisions of this Act, shall be deductible expenses for income tax purposes up to twice the actual amount incurred: Provided, That the deduction shall apply for the taxable period when the expenses were incurred: Provided, further, That all health and nonhealth facilities, establishments and institutions shall comply with the provisions of this Act within six (6) months after its approval: Provided, finally, That such facilities, establishments or institutions shall secure a "Working Mother-Baby-Friendly Certificate" from the Department of Health to be filed with the Bureau of Internal Revenue, before they can avail of the incentive.

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"Government facilities, establishments or institutions shall receive an additional appropriation equivalent to the savings they may derive as a result of complying with the provisions of this Act. The additional appropriation shall be included in their budget for the next fiscal year." 7. REPUBLIC ACT NO. 9999 - Free Legal Assistance Act of 2010 Section 5. Incentives to Lawyers. - For purposes of this Act, a lawyer or professional partnerships rendering actual free legal services, as defined by the Supreme Court, shall be entitled to an allowable deduction from the gross income, the amount that could have been collected for the actual free legal services rendered or up to ten percent (10%) of the gross income derived from the actual performance of the legal profession, whichever is lower: Provided, That the actual free legal services herein contemplated shall be exclusive of the minimum sixty (60)-hour mandatory legal aid services rendered to indigent litigants as required under the Rule on Mandatory Legal Aid Services for Practicing Lawyers, under BAR Matter No. 2012, issued by the Supreme Court. Section 6. Information, Education and Communication (IEC) Campaign. - The DOJ, in cooperation with the Philippine Information Agency (PIA), is hereby mandated to conduct an annual IEC campaign in order to inform the lawyers of the procedures and guidelines in availing tax deductions and inform the general public that a free legal assistance to those who cannot afford counsel is being provided by the State.1avvph!1 8. REPUBLIC ACT No. 1855 AN ACT TO PLACE LIFE INSURANCE COMPANIES ON AN NEW INCOME TAX BASIS BY AMENDING SECTIONS TWENTY-FOUR AND THIRTY-TWO OF COMMONWEALTH ACT NUMBERED FOUR HUNDRED AND SIXTY-SIX, OTHERWISE KNOWN AS THE NATIONAL INTERNAL REVENUE CODE, AS AMENDED. Section 2. Section thirty-two of the National Internal Revenue Code, as amended, is hereby further amended to read as follows: "Sec. 32. Special provisions regarding income and deductions of insurance companies, whether domestic or foreign. (a) Special deductions allowed to insurance companies. In the case of insurance companies, except domestic life insurance companies and foreign life insurance companies doing business in the Philippines, the net additions, if any, required by law to be made within the year to reserve funds and the sums other than dividends paid within the year on policy and annuity contracts may be deducted from their gross income: Provided, however, That the released reserved be treated as income for the year of release.

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"(b) Mutual insurance companies. In the case of mutual fire and mutual employers' liability and mutual workmen's compensation and mutual casualty insurance companies requiring their members to make premium deposits to provide for losses and expenses, said companies shall not return as income any portion of the premium deposits returned to their policy-holders, but shall return as taxable income all income received by them from all other sources plus such portion of the premium deposits as are retained by the companies for purposes other than the payment of losses and expenses and re-insurance reserves. "(c) Mutual marine insurance companies. Mutual marine insurance companies shall include in their return of gross income gross premiums collected and received by them less amounts paid for re-insurance, but shall be entitled to include in deductions from gross income amounts repaid to policy-holders on account of premiums previously paid by them, and interest paid upon such amounts between the ascertainment thereof and the payment thereof. "(d) Assessment insurance companies. In the case of assessment insurance companies, whether domestic or foreign, the actual deposit of sums with the officers of the Government of the Philippines pursuant to law, as additions to guarantee or reserve funds, shall be treated as payments required by law to reserve funds." 9. Republic Act 9442 AN ACT AMENDING REPUBLIC ACT NO. 7277, OTHERWISE KNOWN AS THE “MAGNA CARTA FOR DISABLED PERSONS, AND FOR OTHER PURPOSES Other Privileges and Incentives “SEC. 32. Persons with disability shall be entitled to the following: (a) At least twenty percent (20%) discount from all establishments relative to the utilization of all services in hotels and similar lodging establishments; restaurants and recreation centers for the exclusive use or enjoyment of persons with disability; (b) A minimum of twenty percent (20%) discount on admission fees charged by theaters, cinema houses, concert halls, circuses, carnivals and other similar places of culture, leisure and amusement for the exclusive use of enjoyment of persons with disability; (c) At least twenty percent (20%) discount for the purchase of medicines in all drugstores for the exclusive use or enjoyment of persons with disability; (d) At least twenty percent (20%) discount on medical and dental services including diagnostic and laboratory fees such as, but not limited to, x-rays, 9

computerized tomography scans and blood tests, in all government facilities, subject to guidelines to be issued by the Department of Health (DOH), in coordination with the Philippine Health Insurance Corporation (PHILHEALTH); (e) At least twenty percent (20%) discount on medical and dental services including diagnostic and laboratory fees, and professional fees of attending doctors in all private hospitals and medical facilities, in accordance with the rules and regulations to be issued by the DOH, in coordination with the PHILHEALTH; (f) At least twenty percent (20%) discount on fare for domestic air and sea travel for the exclusive use or enjoyment of persons with disability; (g) At least twenty percent (20%) discount in public railways, skyways and bus fare for the exclusive use and enjoyment of person with disability; xxx The privileges may not be claimed if the persons with disability claims a higher discount as may be granted by the commercial establishment and/or under other existing laws or in combination with other discount programs/s. The establishments may claim the discounts granted in sub-sections (a), (b), (c), (f) and (g) as tax deductions based on the net cost of the goods sold or services rendered: Provided, further, That the total amount of the claimed tax deduction net of value-added tax if applicable, shall be included in their gross sales receipts for tax purposes and shall be subject to proper documentation and to the provisions of the National Internal Revenue Code (NIRC), as amended.” “SEC. 33. Incentives. – Those caring for and living with a person with disability shall be granted the following incentives: (a) Persons with disability shall be treated as dependents under the Section 35 (A) of the National Internal Revenue Code, as amended and as such, individual taxpayers caring for them shall be accorded the privileges granted by the code insofar as having dependents under the same section are concerned; and (b) Individuals or nongovernmental institutions establishing homes, residential communities or retirement villages solely to suit the needs and requirements of persons with disability shall be accorded the following: (i) Realty tax holiday for the first five years of operation; and (ii) Priority in the building and/or maintenance of provincial or municipal roads leading to the aforesaid home, residential community or retirement village.”

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10. REPUBLIC ACT NO. 9400 March 20, 2007 - AN ACT AMENDING REPUBLIC ACT NO. 7227, AS AMENDED, OTHERWISE KNOWN AS THE BASES CONVERSION AND DEVELOPMENT ACT OF 1992, AND FOR OTHER PURPOSES Sec. 3. A new Section 15-A is hereby inserted, amending Republic Act No. 7227, as amended, to read as follows: "SEC. 15-A. Poro Point Freeport Zone (PPFZ). – The two hundred thirty-six and a halfhectare (236.5 has.) secured area in the Poro Point Special Economic and Freeport Zone created under Proclamation No. 216, series of 1993, shall be operated and managed as a freeport and separate customs territory ensuring free flow or movement of goods and capital equipment within, into and exported out of the PPFZ. The PPFZ shall also provide incentives such as tax and duty-free importation of raw materials and capital equipment. However, exportation or removal of goods from the territory of the PPFZ to the other parts of the Philippine territory shall be subject to customs duties and taxes under the Tariff and Customs Code of the Philippines, as amended, the National Internal Revenue Code of 1997, as amended, and other relevant tax laws of the Philippines. "The provisions of existing laws, rules and regulations to the contrary notwithstanding, no national and local taxes shall be imposed on registered business enterprises within the PPFZ. In lieu of said taxes, a five percent (5%) tax on gross income earned shall be paid by all registered business enterprises within the PPFZ and shall be directly remitted as follows: three percent (3%) to the National Government, and two percent (2%) to the treasurer's office of the municipality or city where they are located. "The governing body of the PPFZ shall have no regulatory authority over public utilities, which authority pertains to the regulatory agencies created by law for the purpose, such as the Energy Regulatory Commission created under Republic Act No. 9136 and the National Telecommunications Commission created under Republic Act No. 7925." Sec. 4. A new Section 15-B is hereby inserted, amending Republic Act No. 7227, as amended, to read as follows: "SEC. 15-B. Morong Special Economic Zone (MSEZ). – Duly registered business enterprises operating within the MSEZ created under Proclamation No. 984, series of 1997, shall be entitled to tax and duty-free importation of raw materials and capital equipment. In lieu of all national and local taxes except real property tax on land, a five percent (5%) tax on gross income earned shall be paid by all registered business enterprises which shall be directly remitted as follows: three

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percent (3%) to the National Government, and two percent (2%) to the treasurer's office of the municipality or city where they are located." Sec. 5. A new Section 15-C is hereby inserted, amending Republic Act No. 7227, as amended, to read as follows: "Sec. 15-C. John Hay Special Economic Zone (JHSEZ). – Registered business enterprises which will operate after the effectivity of this Act, within the JHSEZ created under Proclamation No. 420, series of 1994, shall be entitled to the same tax and duty incentives as provided for under Republic Act No. 7916, as amended: Provided, That for the purpose of administering these incentives, the PEZA shall register, regulate, and supervise all registered enterprises within the JHSEZ: Provided, further, That the Conversion Authority and the John Hay Management Corporation (JHMC) shall only engage in acquiring, owning, holding, administering or leasing real properties, and in other activities incidental thereto." Sec. 6. In case of conflict between national and local laws with respect to the tax exemption privileges in the CFZ, PPFZ, JHSEZ and MSEZ, the same shall be resolved in favor of the aforementioned zones: Provided, That the CFZ and PPFZ shall be subject to the provisions of paragraphs (d), (e), (f), (g), (h), and (i) of Section 12 of Republic Act No. 7227, as amended. Sec. 7. Business enterprises presently registered and granted with tax and duty incentives by the Clark Development Corporation (CDC), Poro Point Management Corporation (PPMC), JHMC, and Bataan Technological Park Incorporated (BTPI), including such governing bodies, shall be entitled to the same incentives until the expiration of their contracts entered into prior to the effectivity of this Act. 11. REPUBLIC ACT NO. 10072 - Philippine Red Cross Act of 2009 Section 5. Privileges. - To allow it to fully realize its mandate under the Geneva Conventions, the Statutes of the International Red Cross and Red Crescent Movement and this Act, the Philippine Red Cross shall: xxx (c)Be exempt from payment of all direct and indirect taxes, all provisions of law to the contrary notwithstanding, including value-added tax (VAT), fees and other charges of all kinds on all income from its operations, including the use, lease or sale of its real property, and provision of services. The Philippine Red Cross shall also be exempt from direct and indirect taxes, including VAT, duties, fees and other charges on importations and purchases for its exclusive use. 12

Likewise, all donations, legacies and gifts made to the Philippine Red Cross to support its purposes and objectives shall be exempt from the donor's tax and shall be deductible from the gross income of the donor for income tax purposes or from the computation of the donor-decedent's net estate as a transfer for public use for estate tax purposes. Finally, the Philippine Red Cross shall be exempt from the payment of real property taxes on all real properties owned by it; 12. REPUBLIC ACT 8292 - Higher Education Modernization Act of 1997 Section 4. Powers and duties of Governing Boards. – The governing board shall have the following specific powers and duties in addition to its general powers of administration and the exercise of all the powers granted to the board of directors of a corporation under Section 36 of Batas Pambansa Blg. 68 otherwise known as the Corporation Code of the Philippines; xxx (c) to receive in trust legacies, gifts and donations of real and personal properties of all kinds, to administer and dispose the same when necessary for the benefit of the university or college, subject to limitations, directions and instructions of the donors, if any. Such donations shall be exempt from all taxes and shall be considered as deductible items from the income tax of the donor: Provided, however, That the rights, privileges and exemptions extended by this Act shall likewise be extended to non-stock, non-profit private universities and colleges: Provided, finally, That the same privileges shall also be extended to city colleges and universities with the approval of the local government to city colleges and universities with the approval of the local government unit concerned and in coordination with the CHED; xxx 13. REPUBLIC ACT No. 10390 - AN ACT AMENDING REPUBLIC ACT NO. 7306, ENTITLED "AN ACT PROVIDING FOR THE ESTABLISHMENT OF THE PEOPLE’S TELEVISION NETWORK, INCORPORATED, DEFINING ITS POWERS AND FUNCTIONS, PROVIDING FOR ITS SOURCES OF FUNDING AND FOR OTHER PURPOSES" TITLE IX. – TAX EXEMPTIONS Section 15. Insert a new Section 21-A which shall read: "SEC. 21-A. Gifts and donations of real and personal properties of all kinds to the Network shall be exempt from donor’s tax and the same shall be considered as an allowable deduction from the gross income of the donor in accordance with 13

the provisions of the National Internal Revenue Code of 1997, as amended: Provided, That the allowable deduction shall be equivalent to one hundred percent (100%) of the value of such donation: Provided, further, That the said donation shall be used exclusively for the production of educational, cultural and historical films and documentaries. "Valuation of assistance, other than the money, shall be based on the acquisition cost of the property. Such valuation shall take into consideration the depreciated value of property in case said property has been used." 14. REPUBLIC ACT NO. 10174 - AN ACT ESTABLISHING THE PEOPLE'S SURVIVAL FUND TO PROVIDE LONG-TERM FINANCE STREAMS TO ENABLE THE GOVERNMENT TO EFFECTIVELY ADDRESS THE PROBLEM OF CLIMATE CHANGE, AMENDING FOR THE PURPOSE REPUBLIC ACT NO. 9729, OTHERWISE KNOWN AS THE "CLIMATE CHANGE ACT OF 2009″, AND FOR OTHER PURPOSES

"SEC. 19. Sources of the Fund. – x x x The People’s Survival Fund (PSF) may be augmented by donations, endowments, grants and contributions, which shall be exempt from donor’s tax and be considered as allowable deductions from the gross income of the donor, in accordance with the provisions of the National Internal Revenue Code of 1997, as amended."

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