CRA has appealed the decision of David, R. et al. v. The Queen (TCC) to the Federal Court of Appeal. This case involved six separate appeals with respect to the disallowance of a tax credit by CRA for a purported charitable gift to CanAfrica International Foundation. The judge waived penalties and allowed the cash contribution of the individuals.

The outcome of this case is very different than a number of other CanAfrica cases so it will be interesting to see how the Federal Court of Appeal will handle this, who have typically not been sympathetic to these types of schemes.

To access the decision click here.

We also have a previous blog about this case which can be accessed at: