Principal Issues: Can the Orchestra issue donation receipts for (1) fixed amounts paid by persons participating in an organized trip the Orchestra made to XXXXXXXXXX (the amount is meant to cover all expenses relating to the trip); and (2) for membership dues paid towards the general operations of the Orchestra.
Position: (1) A receipt can be issued for the "eligible' amount of the gift, if any. (2) A receipt can be issued for the "eligible' amount of the gift.
Reasons: Under the proposed split-receipting rules, any benefits to the donors or to persons with whom the donor does not deal at arm's length would result in an advantage under subsection 248(32) and would reduce the amount of the eligible gift.