In Castro v. The Queen 2015 FCA 225, the Minister argued that inflated donation receipts received by the taxpayers were benefits that disentitled them to charitable tax credits either under section 118.1 because they had no donative intent or under subsection 248(30) because they received an advantage exceeding 80% of the fair market value of their donations. The Federal Court of Appeal agreed with the Tax Court’s conclusion that the taxpayers had donative intent and that an inflated donation receipt is not an advantage within the meaning of subsection 248(32). However, the court allowed the Minister’s appeal on the basis that the receipts issued by the charity were invalid by virtue of listing incorrect amounts of cash gifts.