It is one of the more interesting aspects of practising law that allows lawyers to consider the situation when two laws designed for different purposes intersect. Sometimes these differences can cause difficulties, but when used creatively they can be the key to solving difficult problems. One such intersection involves a gift given with a condition subsequent and the revocation tax.
The charities community is well aware that the Canada Revenue Agency (CRA) works to shut down charities it feels are deserving of such a punishment. In some circumstances, notably, but not exclusively, with respect to charities involved in tax shelters, the CRA works to finalize the charity's revocation within thirty days of its Notice of Intention to do so.
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