Practice question
A qualifying non-stock, non-profit university leases a building portion commercially and uses all proved rental revenues actually, directly and exclusively for education. It claims both the rental revenue and leased property must have identical exemption treatment. What distinction did DLSU MAIN draw?
- Revenue use can support the revenue exemption, while commercial use of the leased asset can defeat its property-tax exemption
- Exemption of revenue automatically exempts every asset generating it
- Commercial source necessarily taxes all revenue despite proved educational use
- The institution name alone makes use irrelevant
- Both kinds of taxable item must always be treated as identical
Legal references
- CIR v. De La Salle University, GR196596/198841/198941, November9 2016 MAIN: https://lawphil.net/judjuris/juri2016/nov2016/gr_196596_2016.html MAIN illustrated school-building lease and revenue-use distinction.
- 1987 Constitution: https://lawphil.net/consti/cons1987.html ArticleXIV Section4(3).
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