What are the practical implications of the ATO's draft ruling TR 2004/D19 and how should this ruling be applied ?at the coalface? of donor programs? TR 2004/D19 requires that cultural organisations become more prudent about their donor programs. They need to be sure they know what is appropriate and to make sure that they adhere to guidelines (ie the law!). A fundamental issue for cultural organisations is to make a clear distinction between membership programs (which can provide benefits) and donor programs (for which donors cannot receive benefits if they also get a tax deduction).