Bifalgorithm post · Vente d'un terrain à sa propre société · I. Background

Program Mechanics

Program Mechanics (Vente d'un terrain à sa propre société · I. Background) — "[7] The mechanics of how the GLGI Program worked are set out in the Partial Agree…

Ideas in this flowchart

  • Mechanics and later assessment of the GLGI Program
  • The program mechanics are set out in the Partial Agreed Statement of Facts and summarized in the Tax Court's reasons.
  • Each participant followed a contribution, approval, and license-donation arrangement.
  • The participant contributed cash to a registered charity.
  • The participant had to be approved as a capital beneficiary of the Global Learning Trust (2004).
  • Upon approval, the participant received Licenses.
  • The participant could donate the Licenses to a registered charity.
  • The stated fair market value of the Licenses was approximately four to five times the contributed cash.
  • Mr. Walby and Mr. De Las Alas acknowledge that much of the GLGI Program was a sham.
  • They also acknowledge that the Licenses were worthless.
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Program Mechanics

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Vente d'un terrain à sa propre société

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"[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."

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