CRA has just released a chapter in their Income Tax Folio series for charities and non-profit organizations.   The new part is S7-F1-C1, Split-receipting and Deemed Fair Market Value.  Income Tax Folios are CRA’s official summary of its interpretation on certain income tax matters and this is the first chapter for Folio 1 Charitable Gifts and Deductions. The new folio relates to subsections 248(30) to (41) of the Income Tax Act (Canada), which contain the split-receipting rules and deemed fair market value rule.

Folio S7-F1-C1 provides CRA’s discussion and interpretation of the following:

Meaning of the term gift

Split-receipting – intention to give

Eligible amount of a gift

Advantage in respect of a gift

Nominal threshold

Fundraising guidelines

Fundraising dinners

Charity auctions


Concerts, shows and sporting events

Golf tournaments

Membership fees

Donor recognition

Property subject to mortgage or hypothec

Cost of property acquired

Deemed fair market value rule

Exceptions to the deemed fair market value rule

Non-arm’s-length transactions

Artificial transactions

Substantive gift (selling property and donating proceeds)

Limited-recourse debt

Information not provided by the taxpayer



Folio S7-F1-C1 also includes 6 specific examples for calculating the eligible amount of a gift for fundraising dinners, charity auctions, golf tournaments, membership fees, deemed fair market and substantive gifts.

Here the full text of Folio S7-F1-C1-