•Guidance does not represent a new policy position of CRA
but rather provides information on the current treatment of
fundraising under the Income Tax Act and common law
•As such, the Guidance will have impact on current CRA
audits, not just future audits
•The Guidance is intended to provide general advice only
and is based on principles established by caselaw that fundraising
must be a means-to-an-end, rather than an end-in-itself
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