The appellants participated in the Global Learning and Gifting Initiative (GLGI) tax shelter program, claiming charitable donation tax credits for cash and in-kind software licenses.
The Minister disallowed the deductions.
The Tax Court of Canada dismissed the appeals, applying established jurisprudence that participants in the GLGI program lacked the requisite donative intent because they expected to profit from their participation.
The Court also noted the trust was invalid and the software licenses had only nominal value.
