In Glover v. The Queen, the Tax Court dealt with a donation of software under a gifting arrangement and whether there was donative intent.  The TCC found there was no donative intent and then sided with CRA that the taxpayer cannot claim a tax deduction.  It has taken 12 years from the “donation” for the Tax Court to deal with the case – not sure if this is because the court is completely overloaded or as a result of delay tactics.  The case dealt with the Charitable Technology Trust Gifting Program.