Our bank made a large contribution to the American Cancer Association. This association provides assistance to individuals in all income levels, but I would say the majority are those with need. Would a contribution to this type of non-profit organization qualify as a donation under CRA?

Probably not unless your donation was restricted to serve only those patients who are low- to moderate-income, and you have an acknowledgement from the American Cancer Association that provides details to support that assertion.

I agree.

The simpliest way to determine if an organization or donation would receive "consideration" under the investment test is to ask:

(1) What's the primary purpose of the organization? and
(2)What were the bank's funds used for?

Then look at the definitions and examples of qualified investments contained in the regulation, Q&As and the preamble to the regulation.

If it don't fit, don't force it.

Still include it and document anything that points towards the funds benefitting LMI. You never know with examiners. I have had years where they counted it and some when they didn't. You never know when Cancer has touched the lives of an examiner and the discretion pendulum swings the other way. All they can do is say that it doesn't qualify. It's the same issue with United Way too.