Coleman v. The Queen, 2010 DTC 1096 [at at 3000], 2010 TCC 109, aff'd 2011 DTC 5040 [at 5651], 2011 FCA 82 -- summary under Total Charitable Gifts

The corporate taxpayer was indirectly controlled by the individual taxpayer. The two taxpayers contributed funds to a charitable organization that provided bursaries and scholarships. The organization's program was to have prospective students at various Christian colleges solicit donations. The student would then be eligible for a bursary generally of 80% of the amount raised and a scholarship of up to 20%. Because the candidates soliciting the taxpayers' donations were the individual taxpayer's children, Miller J. found that the contributions were not charitable gifts. He found at para. 35 that the taxpayers had an "understanding, indeed a knowledge, at the time of the donation, that 80 to 100% of monies they donated would go to cover the education cost of those students who solicited the funds - primarily their offspring."