Federal Appeal


Tax

Income tax

Special rules

Issuance of tax receipts for gifts to unrecognized beneficiaries sufficient for revocation of registration

Minister revoked charitable registration of gallery. Gallery appealed. Appeal dismissed. Although promotion of art might be end benefiting community, evidence demonstrated sales of paintings for benefit of artists rather than promotional activities. Donations to unrecognized beneficiary were not in keeping with objects of gallery. Issuance of tax receipts for gifts to unrecognized beneficiaries was sufficient ground in itself for revocation of registration. Minister’s decision was reasonable.

La Galerie Fôkus c. Canada (Revenu national) (2018), 2018 CarswellNat 6011, 2018 CAF 198, J.D. Denis Pelletier J.A., Boivin J.A., and de Montigny J.A. (F.C.A.).

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