Malone v. Canada

Decided: 2026-10-02. Docket: A-311-25; A-312-25. Citation: 2026 FCA 166 (CanLII). Taxation — Charitable donations — Donation tax credit — Income Tax Act, s. 118.1 — Purported charitable donations under the Global Learning and Gifting Initiative — Whether donation tax credits were properly denied — Donative intent, valuation, and ownership findings upheld — Appeals dismissed | Procedure — Reasons for judgment — Sufficiency — Appellate review — Whether the Tax Court’s reasons were insufficient under R. v. Sheppard and R. v. R.E.M. — “Middle step” between conclusions and evidence alleged missing — Reasons read with record and submissions — Appeals dismissed | Taxation — Charitable gifts — Donative intent — Objective test — Whether appellants lacked donative intent given “win-win” expectation