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–Not necessary that the advantage be received from the charity that received the gift - advantage could be provided by third parties unbeknownst to the charity
–CRA’s administrative exemption applies where there is a token advantage of the lesser of 10% of the value of the gift and $75 (de minimis threshold)
–Example - A charity receives a gift of land from a donor who has received some type of benefit from a developer who owns property adjacent to the donated property in exchange for making the gift
–Naming rights are not advantages if there is no prospective economic benefit associated with the naming rights
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