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LEGAL AND TAX OPINION
Harris, Sheaffer L.L.P. is the Toronto law firm retained by Universal Barter Group Inc. to provide a tax opinion and interpretation of the Income Tax Act as it relates to the UBG Program.
Subsection 248 (1) of the Income Tax Act defines "property" to include a "right of any kind whatever". A barter dollar is property that can be donated as long as it:
1. Is a legally enforceable right
2. Can be transferred without restriction
3. Does not expire
The fair market value is a smaller issue than with other donations "in kind" since there is a relationship between the TradeBUX™ and the fair market value of the merchandise/services available to be redeemed.
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