Program Mechanics

"[7] The mechanics of how the GLGI Program worked are set out in the Partial Agreed Statement of Facts and are summarized in the reasons of the Tax Court. Essentially, each participant in the GLGI Program would contribute cash to a registered charity and, upon being approved as capital beneficiary of the Global Learning Trust (2004), such participant would receive the Licenses that they could donate to a registered charity. The fair market value of the Licenses was stated to be approximately 4 to 5 times the amount of cash they contributed. Mr. Walby and Mr. De Las Alas now acknowledge that much of the GLGI Program was a sham and the Licenses were worthless."