The appellant appealed reassessments disallowing charitable donation tax credits for the 2002 and 2003 taxation years.
The appellant participated in a leveraged donation program where he received interest-free loans for 80% of his purported donations.
The Tax Court of Canada found that the appellant received a significant benefit in the form of the interest-free loans, which vitiated the donative intent required for a valid gift under the Income Tax Act.
The appeal was dismissed.
