CRA comments on directed gifts to a municipality

Regarding a situation where a municipality issued a press release in which it solicited donations that were redistributed to a specific fund for individuals following an unfortunate event, CRA stated:

[D]onations can be receipted by a municipality in Canada on behalf of a program or entity which operates under the authority of the municipality (e.g., a committee established by a municipal bylaw) provided the municipality retains discretion as to how the donated funds are to be spent. If a municipality is merely collecting funds from donors that will simply be redistributed to a person or organization that is not a qualified donee and the latter is legally or otherwise entitled to the property so transferred, the municipality is not in receipt of a gift and cannot issue a donation receipt.

Neal Armstrong. Summary of 2 April 2024 External T.I. 2024-1005231E5 under s. 118.1(1) – total charitable gifts.