| 19(1) | 5-8880 |
| A. Humenuk | |
| 957-2135 |
December 20, 1989
Dear Sirs:
Re: Charitable Gifts
We are replying to your letter of October 12, 1989, concerning personal living and travelling expenses incurred by individuals while travelling on behalf of the 24(1).
24(1)
In order to qualify as a charitable gift for the purpose of sections 110.1 and 118.1 of the Act, the amount must, among other things, be a voluntary transfer of property given without expectation of return. In our view the payment of costs that an individual has incurred in travelling does not constitute a voluntary transfer of property even if the individual has voluntarily contributed his time. There is, however, nothing to prevent the registered charity from fully reimbursing a delegate's reasonable travel costs and later accepting the return of all or a portion of the payment as a gift; provided that it is returned voluntarily. If the delegate is under moral or legal obligation to return a portion of the reimbursement, it is not a gift.
We trust this information will be of assistance to you.
Yours truly,
P.D. Fuocofor DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch