Milot Law has recently been engaged, to file a number of appeals in the Tax Court of Canada, by dozens of participants in the Universal Barter Group (“UBG”) donation program.


The appeals relate to a claim by Canadian taxpayers to a tax credit, in the 2007 and 2008 taxation years, in respect of the donation of barter trade currency (or TradeBUX) to Canadian registered charities.

The Canada Revenue Agency (Appeals Division) has taken the position that the entire amount of the donation should be denied, and has recently started issuing Notices of Confirmation.  A Notice of Appeal must be filed in the Tax Court of Canada within 90 days of the date of the Notice of Confirmation.

The main issues are (1) whether the taxpayers intended to make a gift, and (2) the fair market value of the TradeBUX.  The CRA has made a number of allegations, including that the donation receipts were “inflated”, that participants intended to “enrich themselves”, and that all of the transactions involved with the UBG program were a “sham”.

Milot Law will continue to be in contact with UBG participants and intends to proceed to the Tax Court of Canada as a group, which is cost-effective for all parties.

If you are interested in joining the Milot Law UBG Tax Appeal Group, please contact us at 416-601-1002 or by email at

Milot Law are Canadian Tax Lawyers, in Toronto, which specialize in Canadian Tax Law disputes with the Canada Revenue Agency and the Department of Justice.