CRA will generally not consider advance ruling requests for leveraged donation schemes such as the one considered in Maréchaux. CRA listed conditions under which it would refuse to make a ruling. In addition to five factors present in a Maréchaux-style scheme (essentially amounting to leveraging a donation with "borrowed" funds that do not represent a genuine economic burden on the donor or gain to the charity), the list included:
- The funds loaned to the taxpayer circle back to the lender.
- The use of a limited partnership or other structure permits losses or other deductions to flow through to investors.
- Offshore money managers or investment accounts are used.
- There is uncertainty about certain aspects such as valuation and questions of fact such as arm's-length issues.