•Anti-Avoidance Transaction
–Where a registered charity entered into a transaction (which may include an inter-charity gift) where it “may reasonably be considered that a purpose of the transaction was to avoid or unduly delay the expenditure of amounts on charitable activities
–Applies regardless of whether the two charities are at arm’s length
–110% penalty – if inter-charity transfer, both charities are jointly and severally, or solitarily liable for the penalty
–Both charities risk revocation
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