By David Stevens*
Goodman and Carr, LLP and Faculty of Law, McGill University.
INTRODUCTION
Registered charities and other not-for-profit corporations benefit from
special tax treatment. All not-for-profit corporations are exempt from
taxation on their income.1
As well, registered charities can issue donation receipts, which entitle
individual donors to a tax credit and corporate donors to a tax deduction.2
To maintain their special status, not-for-profit corporations and registered
charities must meet certain requirements of the Canada Customs and Revenue
Agency. In Québec, a parallel registration regime exists, which
mirrors federal requirements.
The tax legislation and regulations governing not-for-profit organizations,
and particularly charities, are quite restrictive. Depending on the goal,
it may be possible to address certain regulatory restrictions by organizing
activities into several inter-related corporations. A number of such interlocking
structures are discussed at the end of this chapter.
NOT-FOR-PROFIT CORPORATIONS
Not-for-profit corporations that are not charities, and that fall within
the definition of "non-profit organizations" set out in Section 149(1)(l)
of the Income Tax Act, do not, in general, pay tax on their income,
but are subject to tax on income from investments or property, and may
be subject to other types of tax - e.g., Goods and Services Tax, sales
tax or property tax. In some cases not-for-profit corporations may qualify
for exemptions or preferential rates, by meeting the definition or requirements
found in the legislation or regulations establishing the tax. Maintaining
non-profit status for purposes of the exemption on income tax requires
that the not-for-profit corporation not permit any income from corporate
operations to flow as a personal benefit to members. There is a limited
exception to this requirement for certain amateur athletic associations.3
Non-profit organizations are also precluded from earning and accumulating
excess income beyond what is considered reasonable to meet the organization's
purposes.4
CHARITIES
The Income Tax Act gives "registered charities" and "qualified
donees" the right to issue donation receipts. Qualified donees, as defined
in the Income Tax Act, include organizations that are not necessarily
charitable at law but that the government deems worthy of donation support.5
Qualified donees include, but are not limited to, registered Canadian
Amateur Athletic Associations, Canadian municipalities, the United Nations
and its agencies, and certain foreign universities and charities.
Registered Charities
"Registered charity" is defined in the Income Tax Act as
a "charitable organization, private foundation or public foundation" that
is resident in Canada, that was established or created in Canada, and
that is registered with the Minister of National Revenue.6
"Charitable organization", "private foundation", and "public foundation"
are each separately defined and regulated under the Act.7
All registered charities must be "exclusively charitable" in purpose
and in actual fact. While the Income Tax Act defines almost all
of the permissible and impermissible activities of registered charities
against this standard, it does not define "charity." Instead, the Canada
Customs and Revenue Agency and the courts rely on the common law definition
of charity.
There are two main sources for this common law definition: the 1601 Preamble
to the Statute of Elizabeth8
and the test set out in the reasons of Lord Macnaghten in the 1891 House
of Lords decision in Commissioner for Special Purposes of the Income
Tax v. Pemsel.9
The Preamble (rendered from archaic to modern language10),
defines charity as:
. . . relief of aged, impotent and poor people . . . the maintenance
of sick and maimed soldiers and mariners, schools of learning, free
schools, and scholars in universities . . . repair of bridges, ports,
havens, causeways, churches, seabanks and highways . . . education
and preferment of orphans . . . the relief, stock or maintenance
for houses of correction . . . marriages of poor maids . . . supportation,
aid and help of young tradesmen, handicraftsmen, and persons decayed
. . . relief or redemption of prisoners or captives, and for aid
or ease of any poor inhabitants concerning payments of fifteens,
setting out of soldiers and other taxes.11
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Although the Statute of Elizabeth was repealed long ago, the
Preamble has been 'absorbed' into the common law, and continues
to influence Commonwealth jurisprudence on the definition of charity.
A modern reader is supposed to read it by analogy to their own time.
In Pemsel, Lord Macnaghten laid out the following classifications
of charity:
"Charity" in its legal sense comprises four principal divisions:
trusts for the relief of poverty; trusts for the advancement of
education; trusts for the advancement of religion; and trusts for
other purposes beneficial to the community, not falling under any
of the preceding heads.12
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The Pemsel test is a classification, not a definition, but is
a useful starting point for an analysis of "charity".
These two tests, and the substantial jurisprudence that interprets and
applies them, have been especially important in the law of trusts where
qualifying as "exclusively charitable" is essential to the validity of
a purpose trust, subject to a few minor exceptions. The same requirement
is imposed on entities seeking charitable registration under the Income
Tax Act. In applying these tests, courts require that the
purpose of the entity or trust be exclusively charitable and that the
entity or trust be for the "public benefit". This means, in general terms,
that the charity must pursue the relevant charitable purpose for the benefit
of a large enough segment of society, "the public", in an effective way.
Charitable organizations
Charitable organizations are distinguished from foundations by
their active orientation - generally, charitable organizations carry out
their own charitable activities. A charitable organization must devote
all of its resources to the charitable activities that it con-ducts. It
must not distribute or make available any part of its income to, or for
the benefit of, individuals or parties other than the intended beneficiaries.
Certain exceptions apply to various aspects of the standard requirements
these organizations must meet. Charitable organizations may make grants
totalling not more than fifty percent of their income in any one year
to qualified donees. They are allowed to carry on a 'related business'.
And they may disburse their income to an 'associated' charity.13
Charitable organizations may be organized as trusts, corporations or associations.
EXAMPLE
Granting - an organization without a well-developed infrastructure
in a geographical area that it is mandated to serve may make grants
to a local organization (also a registered charity) in that location
to achieve its purposes.
EXAMPLE
Related business - a social service organization may operate
a thrift shop in support of its work, or a hospital may run a cafeteria
and apply the profits from sales of food to its general revenues.
EXAMPLE
Associated charity - an organization may fund a related
organization (also a registered charity) that is mandated to carry
out a particular part of its work, such as the provincial chapter
of a national organization.
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Foundations
Foundations are characterized by their passive orientation -
generally, they fund charitable activities that are carried on by other
organizations. Foundations must be constituted and operated exclusively
for charitable purposes. "Charitable purposes" includes the disbursement
of funds to qualified donees (including registered charities).14
No part of a foundation's income may be available for the personal benefit
of any individual or party that is not an intended beneficiary of the
foundation's purposes.15
Foundations must be organized as trusts or corporations. They may not
be organized as unincorporated associations.16
Executives of registered charities and sources of capital
The Income Tax Act includes provisions about the makeup
of the executive (officers, directors, and trustees, etc.) of registered
charities and about their sources of capital.
Generally, if the registered charity is to be a charitable organization
or a public foundation, rather than a private foundation, more than fifty
percent of its executive must deal with each other, and with each of the
other members of the executive, at arm's length17
and not more than fifty percent of its capital may have been contributed
by one person or by one group of persons who do not deal with each other
at arm's length. Determination of whether a relationship is arm's length
is made by looking at the extent of the kinship and/or business or other
connections between the parties. If the registered charity is classified
as a private foundation, it is subject to more stringent regulations.
The Income Tax Act provides an exception allowing, in some instances,
governments, charitable organizations, public foundations, clubs, societies,
and associations to establish public foundations or charitable organizations
by contributing fifty percent or more of the capital.18
The charitable registration process
Canada Customs and Revenue Agency Charities Directorate examiners
decide whether an organization applying for federal charitable registration
qualifies based on an assessment of whether it meets the legal definition
of charity discussed above.
The Canada Customs and Revenue Agency is not obliged to hear or receive
submissions from the applicant. The Charities Directorate does, however,
have in place a standard procedure for obtaining clarifications of, or
additional information on, problem applications. The applicant may appeal
a negative decision to the Federal Court of Appeal.
De-Registration
A charity may be deregistered for:19
- failing to comply with the annual information return requirement;
- issuing an improper or false donation receipt;
- failing to continue to meet any of the requirements of registration,
including:
- carrying on any business, if it is a private foundation, or an
unrelated business, if it is a charitable organization or public
foundation;
- if it is a foundation, acquiring control of any corporation or
incurring certain types of debts;
- attempting to unduly delay its expenditure on charitable activities
by making transfers to another charity;
- failing to disburse a set proportion of its assets or funds receipted
in the previous year for charitable purposes or activities; or
- failing to keep proper records and books of account.
The decision to revoke a registration is made by the Minister under section
168(1) of the Income Tax Act. The Minister gives notice of his
intention to revoke by registered mail and offers the charity an opportunity
to respond.
Most revocations stem from failure to file the information return. Occasionally,
revocations are triggered by audits. Where revocation results from failure
to file, organizations should not assume automatic renewal of registration
once they file the proper paperwork. Changes in the legal definition of
charity over time may mean they no longer qualify.
Revocation can happen as early as thirty days later by publication of
the Minister's decision to revoke in the Canada Gazette, although
usually the process goes on for some time. The charity may appeal to the
Federal Court of Appeal.20
THE REGULATION OF CHARITIES
The Income Tax Act and/or the Canada Customs and Revenue Agency
regulate the investment, business, political, borrowing, granting, and
international activities of charities. The Income Tax Act also
man-dates certain levels of disbursements for all charities. The regulations
pertaining to charitable organizations can be reduced to two basic rules:
1) A charity must be exclusively charitable.
Foundations must be "constituted and operated exclusively for charitable
purposes." Charitable organizations must devote "all their resources ...
to charitable activities carried on by the organization itself". This
means a charity cannot pursue any other purpose - business, investment
return, political - except to the extent that it is incidental and ancillary
to the charitable purpose or is a means of achieving it. Many of the rules
discussed in this chapter either apply more specific requirements to this
standard or accommodate certain acceptable practices.
2) A charity must spend a certain percentage of its funds on
charitable activity.
The Income Tax Act requires that charity be done to
a certain quantified benchmark by requiring certain levels of disbursement
of funds on charitable activity. These levels are different for charitable
organizations and foundations. This required spending is known as the
"disbursement quota".
Control of corporations
Foundations may not "acquire control" of a corporation. This
prohibition does not apply, however, to a foundation gaining control of
a corporation by gift.
Investments
The Income Tax Act does not require that a charity's
investments earn a specific rate of return. It addresses the issue of
investment return only indirectly, by imposing a 4.5% disbursement quota
on foundations. Private foundations are subject to certain more detailed
and restrictive rules to ensure against manipulation of transactions to
artificially reduce the disbursement quota, and to preclude financial
benefits being gained by non-arm's length individuals or parties dealing
with the private foundation.21
Business activities
A registered charity, whether it is a charitable organization
or a foundation, is not allowed to conduct an unrelated business. Doing
so would violate the exclusively charitable requirement.
Charitable organizations are allowed to carry on a related business.
A charity that operates a related business is considered under the Income
Tax Act to be devoting its resources to its charitable activities.
Nothing in the Income Tax Act makes reference to public foundations
in this regard. They are, therefore, allowed to carry on related businesses.
Private foundations are explicitly prohibited from carrying on any business,
related or unrelated.22
Political activities
Registered charities are permitted to engage in political activities
under the Income Tax Act, but only to a very limited extent.
Their right to do so is regulated by two sets of rules, the first related
to the definition of charity, the second to the disbursement quota.
- Registered charities are allowed to engage in political activities
that are ancillary and incidental to the charity's purposes. Political
activity is accept-able provided that the charity devotes "substantially
all" of its resources to charitable purposes, and only a part of its
resources to non-partisan political activities of an "ancillary and
incidental" nature. "Resources" includes all financial, physical, and
human resources owned by or available to the charity, not just those
that come from receipted donations. The Canada Customs and Revenue Agency
defines "substantially all" as ninety percent or more of the resources.23
- Registered charities must respect their disbursement quota when allocating
resources to political activity, creating an additional constraint on
such activity. The amount a registered charity spends on political activities
does not count as an expenditure on charitable activities or as a gift
to a qualified donee for the purposes of satisfying the disbursement
quota.24
Since these quotas are quite high, there is not much room in the budgets
of most charities for permissible political expenses.
Borrowing activities
Charitable organizations are allowed to borrow, if the power
to borrow is provided for in their bylaws. Foundations are not allowed
to incur debts for purposes other than current operating expenses, purchase
of investments and administration expenses.
International activities
A registered charity must be resident in Canada. This significantly
restricts the capacity of Canadians and Canadian charities to do charity
abroad. There are, how-ever, three ways under the Income Tax Act that
a registered charity can do charitable work outside of Canada.
- A registered charity may carry on its own charitable activities abroad.
Practically speaking, however, this option is open to only a few large
and well-established charities, such as relief organizations, which
have the financial and administrative resources to send their people
abroad.
- Sections 110.1(1)(a) and 118.1(1) of the Income Tax Act
allow deductions and credits for gifts to the United Nations or
any of its agencies, to prescribed foreign universities and to charitable
organizations outside Canada to which the Canadian government has made
a recent gift. This permits a limited amount of international charitable
activity, but the list of eligible donees is very restricted.
- A Canadian charity can enter an agency relationship with an entity,
usually a foreign charity, which will do the actual charitable work
abroad on behalf of the Canadian charity.
THE TREATMENT OF GIFTS TO REGISTERED CHARITIES AND QUALIFIED
DONEES
Gifts
There is no definition of "gift" in the Income Tax Act.
Therefore, the courts use the private law - i.e., common law or civil
law - definition of the term when applying the provisions of the Act.
The common law definition of a gift is stated in Friedberg v. MNR:25
a gift is a voluntary transfer of property owned by a donor to
a donee, in return for which no benefit or consideration flows to
the donor.26
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Similarly, article 1806 of the Civil Code of Quebec defines
a gift as follows:
Gift is a contract by which a person, the donor, transfers ownership
of property by gratuitous title to another person, the donee; a
dismemberment of the right of ownership, or any other right held
by the person, may also be transferred by gift.
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The Canada Customs and Revenue Agency's position on the meaning of "gift"
is set out clearly and comprehensively in Interpretation Bulletin 110-R3,
"Gifts and Official Donation Receipts."27
IT-110-R3 defines a gift as follows:
A gift ... is a voluntary transfer of property without valuable
consideration. Generally a gift is made if all three of the conditions
listed below are satisfied:
- some property - usually cash - is transferred by a donor to
a registered charity;
- the transfer is voluntary; and
- the transfer is made without expectation of return. No benefit
of any kind may be provided to the donor or to anyone designated
by the donor, except where the benefit is of nominal value.28
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A gift is a transfer of property, not of services. No donation credit
is available for the performance of services rendered without remuneration
or compensation.29
A professional who wants to receive a donation receipt for time and professional
skill donated to a charity must first bill the charity for the services
performed and then donate the amount he or she is paid back to the charity.
A gift can be a gift of a legal or an equitable interest, so the settlement
of a trust which creates an equitable remainder interest in favour of
a charity is a gift of that equitable remainder interest.
A loan of property is not a gift of property because no title or right
passes by virtue of a loan.
Gifts in kind are gifts of property. A gift in kind is usually valued
at the amount that would have been received for the property if it had
been sold on the open market to an informed, unrelated party on the date
the gift was made.
The transfer cannot be a transfer pursuant to a legal obligation. The
Canada Customs and Revenue Agency has recently stated, for instance, that
a gift made pursuant to a legal obligation to make it - e.g., a promise
by a child to make a gift of property received by bequest from a parent
- is not a gift.30
In order to be a gift, property must be transferred to the charity. But
the transfer can, in some instances, be subject to conditions and restrictions.
This allows for the creation of 'donor-advised' or 'donor-designated'
gifts. Restrictions on the uses of the gift can also be imposed through
creation of a charitable purpose trust.
The Canada Customs and Revenue Agency does not permit gifts to be directed
to specified persons or families. This means that a charity cannot accept
a gift on the condition that it gift the property to another person.
A transfer where any part of the transaction can be said to be for consideration
usually will not constitute a gift.
EXAMPLE
The Canada Customs and Revenue Agency takes the position
that a transfer of land worth $100,000, subject to a mortgage of
$25,000, which the charity assumes, may not be a gift because the
charity - in assuming liability under the mortgage - may be giving
consideration to the donor. Specifically, if the donor has guaranteed
the mortgage through a personal covenant, relief from this obligation
constitutes consideration.
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There are three exceptions to this: in IT-110R3, the Canada Customs and
Revenue Agency states that it will permit a charity to issue a receipt
for the gift portion of payments made to a charity at a fundraising event,
such as a dinner or golf tournament. It takes a similar approach to tuition
fees paid for religious education and to charitable gift annuities.
There have been a number of decisions in recent years that have been
generally supportive of Canada Customs and Revenue Agency's position.
It is worth mentioning one in particular. In Woolner v. The Attorney
General of Canada,31
the Federal Court of Appeal found that donations to a church were not
gifts. The taxpayers had made contributions to the their church and received
charitable donation receipts in exchange. The church used the funds to
award educational bursaries to the contributors' children. The Court found
that the plaintiffs made their contributions in the expectation that their
children would be provided with a bursary, not as a gift to the church.
The treatment of receipted donations
The credit for individuals
Individuals who make donations to registered charities and other
qualified donees are entitled to a federal tax credit. This applies to
donations of up to 75% of the donor's income in the year. This increases
to 100% of the donor's income in the year of death and in the year preceding
death. "Cultural gifts" and "ecological gifts" may be used to the entire
extent of an individual's income in the year. These are defined terms
under the Income Tax Act.
The federal credits are equal to 16% on the first $200 donated and 29%
on the remainder. Provincial credits vary from province to province, from
a high of 24.5% in Quebec to a low of 11.16% in Ontario.
Donation credits may be carried forward five years.32
The tax credit for gifts made by the taxpayer in the year of death can
be carried back to the preceding year to the extent that they cannot be
used in the year of death.33
Individuals may claim credits for receipts issued in a spouse's name.
Disbursement quotas
Registered charities are required to devote a specific percent
of their income to charitable activities or to gifts to qualified donees.
Generally speaking, it is accepted that the direct administrative costs
of functioning as a charity qualify as charitable activities, but that
fundraising costs and legal and accounting costs do not.
The quota for charitable organizations
A charitable organization must spend at least 80% of its previous
year's receipted donations on its charitable activities or on gifts to
"qualified donees". Twenty percent represents the government's view as
to how much of a charitable organization's revenue should be used for
non-charitable expenses, such as the cost of administration, fundraising
and political activities. The fact that only receipted gifts are included
means that gifts from tax-exempt organizations (governments and non-profits)
and non-residents and unreceipted gifts do not form part of the pool of
gifts required to be disbursed. Gifts from donors who do not require tax
receipts are excluded, as are gifts made by way of bequest or inheritance
and gifts subject to a trust or a direction that the gifted property (or
property substituted) be held for at least ten years.34
Gifts from one registered charity to another are also excepted.35
The point of these exceptions is to permit charitable organizations to
build up capital endowments with gifts intended for that purpose.
There may be occasions where the disbursement quota cannot be met. In
these situations, the charitable organization may apply to the Minister
to obtain a discretionary exemption for the shortfall.36
There is also provision in the Income Tax Act for carrying any
disbursement quota excess forward five years and back one year.37
The Minister also allows shortfalls in meeting the disbursement quota
in one year to be corrected by increased expenditures the next year.
The quota for public foundations
The quota for public foundations is the total of a number of distinct
elements.
- Public foundations must disburse 80% of receipted donations from
the preceding year, except for those received as capital gifts or from
other charities.
- Public foundations must also disburse 80% of all gifts received from
registered charities in the pre-ceding year, except for those received
as "specified gifts". The specified gift provision permits tax-neutral
transfers of capital between charities. If the donating charity has
invoked the specified gift designation, it may not count as part of
its own disbursement quota.
- Public foundations must also disburse 4.5% of the average total value
of all their investment property, as calculated in a specified way,
owned during the preceding twenty-four month period.38
The underlying expectation is that the foundation should be earning
a real rate of return on its investments close to or a bit more than
4.5%. The disbursement quota is calculated so that there is little opportunity
for capital growth due to investment earnings over the long term.
The provisions that provide for exceptions to the disbursement quota
of charitable organizations at the discretion of the Minister and allow
charities to carry forward and back disbursement quota excesses also apply
to public foundations.
The quota for private foundations
The disbursement quota for private foundations is the same as that
for public foundations except that a private foundation must disburse
100% of the value of its non-specified gifts from registered charities,
instead of 80%, as in the case of public foundations.
Quota shopping and disbursement avoidance
The Minister has the power to designate a charity as being registered
in any one of the three classifica-tions.39
This power is used to prevent a charity from avoiding more onerous disbursement
quotas by manipulating the classification system.
CORPORATE STRUCTURES
There are many varieties of planning which can be implemented which address
some of the difficulties and challenges presented by the rules governing
charities discussed in this chapter.
One common difficulty encountered by some charities is the restrictions
placed on charities conducting political activities. The following structure
is commonly used to address the difficulty:
A not-for-profit corporation unable to qualify for charitable status,
typically because of advocacy activities, may establish a parallel not-for-profit
corporation to carry on the charitable aspects of its mandate (such as
education) (Figure A). Each organization would carry on its own activities
separately, although it might be possible to share needed space and to
share employees. If so, these arrangements must be commercially reasonable
such that no plausible argument can be made that the charitable corporation
is subsidizing the political corporation's activities.
There are a variety of ways to ensure an appropriate link between the
two or control by one of the other. In law, they are autonomous entities
and the charity will be required to abide by all the income tax requirements
and all the requirements under provincial law. However, through the device
of overlapping boards or membership, as illustrated in Figure A, the functions
of both corporations can usually be co-ordinated in a satisfactory way.
Another frequently encountered scenario is a charity that wishes to carry
on some commercial activity beyond what is permitted under the Income
Tax Act. Suppose, for example, that a charity discovers
and develops a commercial opportunity in a business that is not related.
Provided certain conditions are met, it might be possible for the charity
to own the shares of a corporation that carries on the business. That
corporation, in turn, could gift or dividend some or all of its income
to the charity (Figure B).
If the not-for-profit corporation is not a charity, it is taxable on
its property income from the for-profit company (dividends and interest,
if any) and on its capital gains arising on the sale of the shares of
the for-profit company. If the not-for-profit is a charity, it would usually
be entitled to issue a donation receipt for any gift made to it by the
for-profit corporation.
Foundations (but not charitable organizations) cannot, it will be recalled,
acquire control of a corporation. This rule does not prohibit foundations
from being in a position of control by virtue of receiving the shares
by gift. In Ontario, the Charitable Gifts Act prohibits
a charity from owning directly or indirectly more than 10% of a business.
To address these difficulties, the structure in Figure C might be used.
The technique of overlapping boards and/or members can be used to ensure
that the appropriate level of control is maintained.
SAMPLE QUESTIONS FOR PROSPECTIVE DIRECTORS TO ASK THE ORGANIZATION
- What is the tax status of the corporation?
- What measures are in place to ensure that it makes the necessary
Canada Customs and Revenue Agency filings to maintain that status?
- What measures are in place to ensure that it meets all its other
regulatory obligations under the Income Tax Act?
- If the stakeholders have created an interlocking corporate structure
to accomplish their objective(s), has this structure been set up properly,
and are there safeguards in place to ensure that any necessary legal
distinctions between the various entities are maintained?
SAMPLE QUESTIONS FOR DIRECTORS TO ASK THE ORGANIZATION
- Are the corporation's tax and information filings up-to-date?
- Do the corporation's revenue-generating activities comply with the
requirements for maintaining its current tax status? Could creating
a different type of corporate structure better facilitate this type
of activity?
- Do the corporation's advocacy/political activities comply with the
requirements for maintaining its current tax status? Could creating
a different type of corporate structure better facilitate this type
of activity?
- If the corporation is a charity, is it meeting its disbursement quota?
- If the corporation is a charity, does its receipting policy meet
Canada Customs and Revenue Agency requirements?
TAXATION CHECKLIST
SUBJECT
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TO BE CONDUCTED BY
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HOW OFTEN
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COMMENT
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1. Tax/Information filings
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Full board, audit or finance committee
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Annually
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Are the corporation's required filings being submitted on a timely
basis?
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2. Tax status
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Full board
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At inception of the corporation, and when the mandate of the corporation
changes
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Does the corporation have the appropriate tax status (registered
charity or non-profit) in light of its purposes and activities and
given the regulatory requirements associated with the different
types of tax status?
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3. Non-profit status
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Full board
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Annually
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Is the corporation undertaking any activity that could be considered
as conferring a personal monetary benefit on its members?
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4. Charitable status
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Full board
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Annually
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Is the corporation meeting its disbursement quota, and complying
with regulatory requirements relating to receipting of donations?
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5. Revenue-generating activities
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Full board
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Annually
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Do existing or contemplated revenue-generating activities require
that a different tax status be sought, or that an interlocking corporate
structure be created to facilitate them?
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6. Advocacy/political activitiy
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Full board
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Annually
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Do existing or contemplated advocacy/political activities require
that a different tax status be sought, or that an interlocking corporate
structure be created to facilitate them?
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* B.A., LL.B. Practise
based in Toronto. - This
chapter is adapted from a paper first published by The Canadian Tax Foundation.
See 2001 Conference Report: "Impacts on Charity Taxation".
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