25 September 1989 Income Tax Severed Letter AC58567 - Tax Implications of Charitable Donations to Carleton University

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.

5-8567
                                                  R.B. Day
19(1)                                             957-2136

Sept. 25, 1989

19(1)

We are writing in reply to your letter of August 24, 1989, wherein you requested our views regarding the information you received from the Ottawa District Taxation Office as set out in paragraph 4 of your letter.

During our telephone conversations of September 11 and 12, 1989, we discussed in general terms the income tax implications of Charitable Donations to Carleton University.

We are enclosing, for your information, a copy of Interpretation Bulletin IT-110R2 and the Special Release thereto entitled "Deductible Gifts and Official Donation Receipts". Paragraph 3 of the Bulletin defines a gift, for purposes of the Income Tax Act as "a voluntary transfer of property without consideration". A gift can be said to have been made if all of the following conditions are satisfied:

     (a)  Some property, usually cash, is transferred by a donor
          to a registered charity.

(b) The transfer is voluntary.

     (c)  The transfer is made without expectation in return. No
          valuable consideration or benefit of any kind to the
          donor, or anyone designated by the donor, may result
          from the payment.

We hope that these comments and the information set out in the Bulletins, will be of assistance to you.

Yours truly,

for Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch