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•No Allocation of Costs to Fundraising
•Where it can be demonstrated that an activity would have been undertaken without the fundraising component, then 100% of the costs will be allocated to the applicable expenditure (ex: charitable, administrative, or political activity)
•To demonstrate this, the charity must be able to satisfy the “substantially all” test
–If substantially all (90% or more) of the activity advances an objective (or objectives) other than fundraising
–When completing this test, a charity must separate fundraising content from other content
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