Income tax: is a payment of money to an eligible 'umbrella' organisation under a 'preferred donation arrangement' a tax deductible gift if the donor taxpayer or an associate obtains a collateral benefit?

Taxation Determination TD 93/139 states that a payment of money to an eligible 'umbrella' organisation under a 'preferred donation arrangement' is not a tax deductible gift if the donor taxpayer or an associate obtains a collateral benefit.

The arrangements dealt with in TD 93/139 are now covered by TR 2005/13 , which issued today.