The appellant appealed reassessments disallowing charitable donation tax credits claimed for his participation in the Global Learning Gifting Initiative (GLGI) tax shelter.
The Tax Court of Canada found that the appellant lacked donative intent because he expected to receive a financial advantage in the form of tax credits exceeding his cash donations.
Following binding precedent, the Court held that the cash donations could not be separated from the interconnected transactions of the tax shelter.
The appeal was dismissed.