The appellants participated in a leveraged donation program where they pledged a donation amount consisting of cash and a loan from a third-party lender.
They claimed charitable tax credits for the total pledged amount.
The Minister reassessed to deny the credits, arguing the amounts were not valid gifts.
The Tax Court of Canada dismissed the appeals, finding that the appellants lacked donative intent as they received a significant benefit in the form of the loan arrangement.
The court also held that the split-gifting provisions did not apply and that the receipts were spoiled for failing to contain prescribed information.
