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Donation Receipt Generator: open questions and ambiguities (Revision 2)

Read alongside rules.yaml, test-cases.yaml and receipt-templates.md. Revision 1 (30 fetches) left 18 items; the review-resolution pass of 2026-09-25 (24 fetches + Claude-in-Chrome for the CRA search tool + local extraction of the IRS PDFs) closed or labelled most of them. Status per item: RESOLVED (primary source quoted in rules.yaml), PRODUCT ASSUMPTION (no source forbids or requires it; founder-reviewable), or OPEN.

checked: 2026-09-25

Source gaps​

  1. ITA s.248(30)–(32) verbatim text (CA-08, CA-10). OPEN. The laws-lois section-248 page is still too large for the fetch tool. The formulas rest on Folio S7-F1-C1 ¶1.5/1.9/1.12/1.13, Guide P113 and the Split-receipting page, which agree. Folio ¶1.9 (verified) confirms the advantage may accrue to "a person or partnership not dealing at arm's length with the taxpayer". Before go-live, pull the statute text (laws-lois PDF or the XML "FullText" endpoint).

  2. How to print a NOMINAL advantage (CA-09). PRODUCT ASSUMPTION, partly resolved. The Split-receipting page (verified) says a charity "does not have to subtract these advantages from the FMV of the gift when issuing receipts" and gives the $6 mug + $2 pen on a $100 gift as within the $10 threshold. Printing $0.00 with the description "Nominal benefit (FMV $X) — too minimal to affect the amount of the gift (CRA nominal threshold)" is consistent with that; the CRA sample page shows no nominal-advantage sample, so the exact wording is ours.

  3. Electronic signature on a browser-generated PDF (CA-11). RESOLVED as a design decision. Reg. 3501(2) requires a personal signature; (3) and (3.1) are pre-printed-form exceptions, and (3.1) applies only to "another recipient of the gift". The CRA computer-generated guidance is "should". The tool prints a signature block with a required name and title, labels every output "Valid only when signed by an authorized person" (wording that stays true after the treasurer signs the printout), tells the treasurer to keep a copy of the SIGNED receipt, and makes no "read-only/encrypted" claim. Whether to add owner-password PDF encryption is a Phase 2 implementation choice that changes no rule.

  4. Date of donation for e-transfers and post-dated cheques (CA-05). OPEN. The CRA page covers in-person receipt and postmarked mail (verified, incl. "keep the stamped envelope"). Phase 1 applies the general rule (date the charity actually received the funds).

  5. Lost receipts (CA-12). RESOLVED. CRA: "If a registered charity has issued a receipt that was lost or contained incorrect information, the charity can issue a replacement receipt." Same mechanics as a replacement.

  6. Tuition, religious-school fees and the volunteer cheque-exchange (CA-15). OPEN. IC 75-23 and the cheque-exchange guidance were not fetched. Both refer with no advice text.

  7. Registration-number format (CA-00, CA-02). RESOLVED for structure. The CRA List of charities advanced search defines the "BN/Registration number" as "Business number, 9 digits" + "BN Program Account Type, 2 letters" + "bn Program Account Number, 4 digits". "RR" as the charity program letters is shown on the CRA sample receipt and on every List entry; no canada.ca prose page stating "RR" was reachable (BN pages 404). Regex ^[0-9]{9}RR[0-9]{4}$ is enforced.

  8. Per-gift versus aggregate application of the nominal threshold on a cumulative receipt (CA-18). PRODUCT ASSUMPTION (conservative). Reg. 3501(1)(h.1) and Folio S7-F1-C1 speak of "the advantage ... in respect of the gift" (singular); the folio contains no aggregation guidance. Per-gift application can only lower the eligible amount. CA-TC-20 shows the numeric difference ($1,190 vs $1,250). Related PRODUCT ASSUMPTION (final pass): a gift on a cumulative receipt that fails the 80% test is EXCLUDED — not printed on the receipt, not in the totals — and the treasurer sees an on-screen "Not receiptable" notice for it (CA-TC-46); if every gift fails, no receipt is offered (CA-TC-47). The alternative, printing a "not receiptable" row on the official receipt, was rejected because a non-gift should not appear on a receipt at all.

  9. Foreign-currency gifts (CA-19). OPEN / HYPOTHESIS. No CRA page found. Phase 1: CAD only; other currency → refer with "receipt the Canadian-dollar value your church actually received".

United States​

  1. Token / insubstantial-value dollar limits (US-09). OPEN. Pub 1771 prints 2023 figures and says they are inflation-adjusted. US-09 is refer with a single compliant path (disclose the item); the former "check the figures and choose none" path is removed because it omitted the fundraising-campaign and told-the-deductible-amount conditions and mis-measured test 2 (COST, not FMV).

  2. Church-side retention period (US-13). OPEN. No fetched primary source imposes one; IRC s.6001 / Reg. 1.6001-1 not fetched. The tool advises keeping a copy and states no US period.

  3. $250 CWA test — gross payment or net contribution (US-01). RESOLVED: NET. Pub 526 (2025): "If you made a payment that is partly for goods and services, as described earlier under Contributions From Which You Benefit, your contribution is the amount of the payment that is more than the value of the goods and services." US-TC-18 corrected ($250 − $100 = $150: no CWA required; disclosure still required); US-TC-21 added ($350 − $100 = $250: CWA required).

  4. s.6714 verbatim and s.170(f)(12) 30-day rule (US-06, US-11). Half resolved. s.170(f)(12)(C) verified: "within 30 days of the sale of the qualified vehicle" (or of the contribution where the charity certifies retention). s.6714 itself still not fetched; penalty figures from Pub 1771.

  5. Pub 526 fetch quality. RESOLVED. Pub 526 (2025, Feb 5 2026 build) text was extracted from the IRS PDF; the $250 and $75 rules are cited from the correct paragraphs.

  6. Date on the CWA. RESOLVED. Pub 526 requires an annual acknowledgment covering several $250+ gifts to list "each contribution and the date of each contribution"; s.170(f)(17) requires date and amount in the church's written communication for the donor's record.

  7. Mixed tangible goods plus intangible religious benefits (US-02(7)). PRODUCT ASSUMPTION with medium confidence. Reg. 1.170A-13(f)(2) was fetched as a summary (goods "other than intangible religious benefits" get a description/GFE; intangible religious benefits get a statement), and Pub 1771's $75 membership + $20 poster example values only the poster. The fourth goods_status value prints both sentences. Verify the regulation verbatim before go-live.

  8. IRS filing-season opening. The "donors file from late January" warning rests on IR-2025-08 ("the nation's 2025 tax season will start on Monday, Jan. 27, 2025"). The 2026 and 2027 opening dates were not fetched; the tier boundaries (Jan 31 / Apr 15 / Oct 15) are UX heuristics, not per-donor facts.

Product decisions taken (founder-reviewable)​

  1. Signature workflow — see item 3.

  2. Serial numbers — two states (Preview / Issue), treasurer enters the next starting serial from their own log, batch uniqueness asserted, issued-receipts CSV log produced, replacement references the original. Serial arithmetic: trailing digits incremented with the prefix kept; a start with no trailing digits gets "-1", "-2", ... (CA-03, CA-TC-48). Phase 2 option: a browser-local "last serial issued" reminder (per-browser only; never a substitute for the log). CA-03's notes cross-reference THIS item (19), not item 17.

  3. Not-registered path (CA-20) — a plain thank-you letter titled "Thank-you letter — not an official receipt for income tax purposes", stripped of every Reg. 3501(1) element, closing "With gratitude, {charity.name}" with no signer name or title (F-CA-23 absent, so nothing on it resembles a signature block). The word "official" appears on it only inside the two negations. No CRA text forbids it; s.188.1(9) penalizes false statements "on a receipt". Founder to confirm the wording.

  4. Organization donors — now supported (legal name + address), per Reg. 3501(1)(g) "in the case of an individual".

  5. Issue date — device date, not editable, on both CA and US paths.

  6. Phase 2 candidates with fully known field lists: CA gifts in kind (Reg. 3501(1)(e.1), (h)(ii)); US non-cash description-only acknowledgment (Pub 1771 p.6 sample); US token-item exception once the year's figures are sourced; optional PDF owner-password encryption.

  7. US goods line names the gift (US-04, F-US-11). PRODUCT DECISION (final pass). The IRS sample reads "In exchange for your contribution, we gave you a cookbook ..." after a sentence that states the amount and date. On a statement with several gifts that sentence is a table row, so the tool prints one line per gift with goods that carries the gift's amount and date: "In exchange for your contribution of $100.00 on 2026-04-18, we gave you one concert ticket with an estimated fair market value of $40.00." One pattern in the rule, the template and the tests (US-TC-36 has two such lines).

  8. Mixed statements (some gifts with goods, some without). OPEN (UX, not law). The statement sentence (a)/(c) prints once only when every gift gives the same answer; on a mixed statement each gift with goods has its own (b) line and a gift without goods shows "None" in the goods column. Whether to add a per-gift "(a)" sentence for the no-goods gifts on a mixed statement is a Phase 2 wording choice; s.170(f)(8)(B)(ii) is answered per gift either way.