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Question
Harborview Foundation, a non-stock charitable educational organization registered in the Philippines, operates two activities: (i) Exempt activity — a free tutoring program and scholarship fund for underprivileged students; 70% of its receipts come from this program; (ii) For-profit subsidiary — Harborview Digital, Inc., a wholly owned subsidiary that provides online certification courses and professional training to external clients; 30% of total receipts come from the subsidiary. The Bureau of Internal Revenue has issued a preliminary position that the subsidiary income is unrelated business income. (a) Is the subsidiary income exempt, given the Foundation’s exempt purposes? (b) Can Harborview Foundation maintain its tax-exempt status if it continues to operate Harborview Digital? (c) What steps should Harborview Foundation take to preserve its exemption for the exempt activities while addressing the subsidiary’s income?