| October 19, 1990 | |
| K.E. Mannion | Business and General |
| Chief of Audit | Division |
| Winnipeg District Office | Rulings Directorate |
| R.D. Mundell | |
| Attention: G.B. Andrews | (613) 957-2139 |
| Business Audit Section | |
| 7-902523 |
Re: Charitable Donations
This is in reply to your memorandum of September 18, 1990 requesting our comments with respect to whether a claimed charitable donation is a true gift.
24(1)
As you have pointed out, the definition of a gift, as set out in the Burns case, requires that the donor must be aware that he will not receive any compensation other than pure moral benefit; he must be willing to grow poorer for the benefit of the donee without receiving any such compensation.
We agree with your determination that, 24(1)
24(1)
We trust these comments will prove helpful.
B.W. BathDirectorBusiness and General DivisionRulings DirectorateLegislative IntergovernmentalAffairs Branch
c.c. Charities Division