Here is a CRA letter on whether amount paid by Canadian estate to a U.S. charity is a gift to a qualified donee in a particular situation.  It deals with an estate of a deceased who wished to have the estate pay out pay out “amounts for the benefit of the lifetime financial support for his cryopreservation”.

The CRA letter on whether amount paid by Canadian estate to a U.S. charity is a gift to a qualified donee in a particular situation covers various issues including gifts to US charity, who is a qualified donee, and the limitations on using the Canada-US tax treaty.