You're getting to your bottom line in a much more complicated way than you need to. There's a much more direct way of getting to your bottom line than what you're suggesting. You don't need all of those subsections, you can just say that any gift under $200 is acceptable and reportable. That's not the rule at the moment. You could maybe make some kind of an argument....
I don't agree with you that when you read subsection 14(1), it's in the eyes of the donor. It's that it's reasonable to be seen that way by the man on the Clapham omnibus. Legally, it's by the reasonable man. You could add those words if you wanted, to make it clear in that direction, but—