The appellant was a businessman who made his fortune in the oil and gas industry. In order to fructify his capital, he decided to lend money to third parties. When two companies to which he lent money went bankrupt, he claimed business losses in relation to the loans he made to these two companies.
Evidence
Donative Intent, Really?
In this case, the taxpayer withdrew money from his RRSP in 2004. In order to offset the tax he would have had to pay, he made a charitable donation of $65,000 to the Canadian Literacy Enhancement Society (“CLES”). In 2008, the CRA reassessed the taxpayer’s 2004 taxation year to disallow the federal and provincial tax credits he claimed in relation to that payment.