•Pre-2010 Budget DQ Rules – Problems and Issues
•Administrative Difficulties
–Arbitrary Expenditure Requirements
–Not sensitive to operational needs of charities
–Not sensitive to prevailing market conditions
–Ongoing time and expense spent on compliance
•Complicated and Hard to Understand
–Enduring Property Rules
–Capital Gains Pool Concept
–80% DQ Requirements
•Hard to Characterize Expenses
–Administration
–Charitable Activities
–Fundraising
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