Oakville, ON – The Tax Court of Canada has dismissed an appeal by Ontario resident Eric Aidoo, who challenged the Canada Revenue Agency’s (CRA) reassessment of his 2007 income tax return after he claimed more than $28,000 in charitable donation credits linked to the Global Learning and Gifting Initiative (GLGI). The decision in Aidoo v. The King, 2025 TCC 100 (CanLII) was released on July 23, 2025.
In Canada, when you donate to a registered charity, you can claim a tax credit that reduces the amount of income tax you owe. The credit amount depends on how much you donate. To qualify, the donation must be legitimate and supported by an official receipt from a registered charity.
Aidoo represented himself at the hearing, which took place in Oakville on July 7, 2025. Justice John A. Sorensen issued the decision on July 23, ruling that Aidoo failed to establish that his 2007 contribution to GLGI qualified as a genuine charitable gift under the Income Tax Act. The court also found he was wilfully blind to the nature of the program, which has been the subject of extensive litigation in recent years.
GLGI was marketed as a leveraged donation program in which participants made a cash contribution and, in return, received software licences valued at several times the cash amount. Those licences would then be donated to another charity, generating a receipt for a much higher amount than the participant’s out-of-pocket contribution. In Aidoo’s case, he contributed $4,000 and received donation receipts totalling over $28,000, which he used to claim tax credits for 2007.
A leveraged donation is an arrangement where a donor contributes a smaller amount of cash and is promised a much larger donation receipt by adding in goods or services claimed to be worth several times the cash amount. These programs have been repeatedly found by Canadian courts to be abusive tax shelters, meaning they are set up mainly to create inflated tax benefits rather than to help a real charitable cause.
In testimony, Aidoo said he joined GLGI at the urging of his then-fiancée and her family, who had already participated. He told the court that he trusted them, as well as assurances from a financial advisor they knew, and did not investigate the program himself. He also said he did not know about the “Millenium Foundation”, (the charity to which he made his initial donation under the GLGI structure) or its projects, nor did he have any concerns after reading promotional materials. The court noted that Aidoo made no independent inquiries, accepted documents from GLGI without verifying their accuracy, and failed to preserve key records such as his donation receipts.
Justice Sorensen highlighted that Aidoo earned about $65,000 in 2007 and had previously only made donations with a one-to-one relationship between the amount given and the tax result. The GLGI claim produced an unusually large tax benefit, roughly seven times his cash contribution, yet Aidoo maintained he did not realize the size of the refund he would receive. The court found this claim unconvincing, noting that the self-assessment system places a duty on taxpayers to think critically about their filings.
The court also addressed the validity of the Global Learning Trust (2004), a central element of the GLGI program. Consistent with prior cases, the court accepted the Minister’s position that the trust was invalid, meaning participants could not have legally acquired and donated the software licences as claimed. Aidoo did not provide evidence to counter this finding.
The CRA had also argued the program was a sham. While the court found it unnecessary to conduct a full sham analysis, it noted that prior GLGI cases consistently determined the fair market value (FMV) of the donated licences was nominal, further undermining the claim.
The FMV is the price an item would reasonably sell for in the open market between a willing buyer and a willing seller. For tax purposes, the value of donated goods is based on FMV. In many GLGI cases, courts have found that the items claimed as donations, such as software licences, were actually worth little to nothing in real terms.
Aidoo raised additional complaints, including allegations of CRA delay, unfair collection practices, harassment by investigators, and systemic racism. He argued that the CRA targeted minority communities through GLGI’s promotion and requested demographic data on participants. Justice Sorensen ruled these matters were either outside the Tax Court’s jurisdiction or irrelevant to the correctness of the 2007 assessment. The court also found Aidoo provided no reasonable basis for believing the CRA collected or possessed the demographic information he demanded.
For a contribution to count as a charitable gift under the law, the donor must genuinely intend to give something away without getting anything in return. If the donor expects a personal financial gain, such as a large tax refund , that usually means there is no true donative intent.
In dismissing the appeal, Justice Sorensen concluded that Aidoo lacked the necessary donative intent and was wilfully blind to the fiscal advantages of the program. Even if that conclusion were wrong, the court found the appeal would fail on multiple other grounds, including the invalidity of the trust and the inflated valuation of the donated property.
No legal costs were awarded.
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