Law360 Canada ( July 23, 2025, 2:14 PM EDT) -- Appeals by appellants against a decision of the Tax Court dismissing their appeals from reassessments. The appellants participated in the Global Learning Gifting Initiative (GLGI) program. They claimed charitable donation tax credits under the Income Tax Act (the Act) for both cash payments and alleged donations of educational courseware licences (Licences). The Minister of National Revenue reassessed and denied these tax credits, leading to appeals by the appellants. The Tax Court found that the cash payments made by the appellants were not gifts for the purposes of the Act, as they lacked donative intent. The Tax Court determined that the transactions were part of a single interconnected arrangement aimed at profit, not genuine charitable donations. Their appeals from the reassessments were dismissed. The appellants appealed from the reassessments. They argued that the Tax Court erred in treating the transactions as interconnected and in its interpretation of the term “gift.” They contended that the cash payments should be considered valid gifts, as they did not receive any actual value in return....