11 December 1989 Ruling 58943 F - Charitable Organizations

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

Dear: 19(1)

We are writing in reply to your letter of October 17 and November 15, 1989, wherein you asked the following questions regarding 24(1)

Our Comments

24(1)

Under the disbursement quota provisions in the Income Tax Act, charitable organizations are required to disburse 80% of donations in respect of which the organization issued receipts in the immediately preceding taxation year. In determining this amount, the following gifts are excluded even though proper receipts were issued:

a)     capital gifts received by bequest or inheritance;

b)     gifts subject to a trust or direction to the effect that the property in question, or substituted property, be held by the charitable organization for at least ten years; and

c)     gifts received from other registered charities. 

In view of the above, 24(1)

We hope these comments will be of assistance to you.

Yours truly,

for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch