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f)Tax Shelter
Cases
Berg
A. V. The Queen (2012 TCC 406) involved a series of
pre-determined donation transactions with (YITI) and SVG
Bancorp:
B purchased timeshare units in 2002 with a cash payment
of $200,000 and $2.2 million promissory note in favour of YITI
B
pledged the timeshare units to YITI as security for his obligations
under the promissory note and was provided with a written
discharge of his obligations
B transferred the units to a charity and received a donation
receipt for $2.4 million with which a claimed a charitable donation
tax credit
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