The short answer is no. If we take a look at the U.S. system, we see that it's so different from what's here in Canada. There are fundamental issues. First, it doesn't really fit. Our system has been based on the common law premise that's more general than the U.S. Internal Revenue Code rules, which are more black and white. By importing one small section from the complex U.S. tax regime, we're mixing systems with unsatisfactory results.
The second challenge is that the U.S. system is incredibly prescriptive; even the current CRA guidance format allows the charity to figure out the best accountability instrument. Essentially what's happening is that this prescriptive approach takes out the context. It's trying to say that every charitable partnership needs to look the same, and that's not the way it works on the ground. We need a system that allows charities, non-qualified donees and, yes, CRA to work together to find good demonstrations of accountability.