Colonel J.C. Brace Base Commander Canadian Forces Base Trenton 900344 Astra, Ontario W.P. Guglich K0K 1B0 (613) 957-2102
Attention: Captain A.N. Marcoux
This is in reply to your letter of January 16, 1990 wherein you requested our views as to whether donations to the 24(1) could be considered gifts to Her Majesty.
24(1)
It is our view that donations to the 24(1) could be considered gifts to Her Majesty for purposes of sections 110.1 and 118.1 of the Income Tax Act (the "Act"). Receipts may be issued, to provide proof of such gifts to Her Majesty, in accordance with subsections 110(2) and 118.1(2) of the Act and sections 3500 and 3501 of the Income Tax Regulations. A copy of section 3500 and 3501 of the Income Tax Regulations is attached for your convenience.
We note that the fund raising activities of the 24(1) should be conducted in such a way that ensures the donations are paid to the 24(1) itself (or to a responsible Crown official acting in his official capacity on behalf of the 24(1) and not to a separate entity which is merely assisting the 24(1)
We trust this will be of assistance to you.
Yours truly,
for Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch