7.22. The amount of the advantage in respect of a gift made by a taxpayer is equal to the aggregate of(a) the aggregate of all amounts, other than an amount referred to in paragraph b, each of which is an amount equal to the value, at the time the gift is made, of a property, service, compensation, use or other benefit that the taxpayer, or a person or partnership who does not deal at arm’s length with the taxpayer, has received, obtained or enjoyed, or is entitled, either immediately or in the future and either absolutely or contingently, to receive, obtain, or enjoyi. that is consideration for the gift,
ii. that is in gratitude for the gift, or
iii. that is in any other way related to the gift; and
(b) the limited-recourse debt, determined under section 851.41.1, in respect of the gift at the time the gift is made.