Tax deductions for US citizens and corporations on US donations to Canadian charities with reciprocal 510(c)(3) status

I have tried reading other answers and past commentary as well as legal analysis, but… still don’t feel I have a confident answer.

Let’s say Joe and Company A both are based in the US and receive income/revenue only in the US. Charity M is a Canadian registered charity that under the tax agreement has received reciprocal 501(c)(3) status in the US. Am I correct in my understanding that:

1. Donations Joe and Company A make to the Charity M are NOT deductible against their US taxes because they do not have any Canadian-based income, even though Charity M does have 501(c)(3) status in the US?

2. Charity M would NOT legally be able to use its funding to support its own activities if they were US-based and benefited US citizens because Charity M was created and is based in Canada?

Relevant: On September 10, 1999, the IRS released Notice 99-47, providing guidance on the U.S.-Canada treaty. The Notice states that, if a U.S. donor makes a gift to a Canadian registered charity, the Canadian charity will be deemed to be a private foundation under U.S. law, unless the Canadian charity provides the IRS with the financial information needed to determine its proper classification. Also, the Canadian charity will not be listed in IRS Publication 78 – Cumulative List of Organizations, unless it provides this information. If the Canadian charity is deemed to be a private foundation, the U.S. donor’s income tax deduction will be limited to 30% of the donor’s Canadian source income. (source https://www.irs.gov/charities-non-profits/charitable-organizations/charitable-contribution-deductions)

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