April 13, 2010

CRA Issues Notice of Suspension to International Relief Fund for the Afflicted (IRFAN-Canada)

The Charities Directorate of the CRA has issued a Notice of Suspension to International Relief Fund for the Afflicted (IRFAN).  Prior to this suspension there was only 1 other charity that was suspended.  CRA is making greater use of the intermediate sanctions - ie suspensions or penalties rather than revocation. Here is a copy of the CRA press release. 

http://www.cra-arc.gc.ca/nwsrm/rlss/2010/m04/nr100413c-eng.html

News release The Canada Revenue Agency issues Notice of Suspension to International Relief Fund for the Afflicted and Needy-Canada
Ottawa, Ontario, April 13, 2010… The Canada Revenue Agency (CRA) has issued a Notice of Suspension to the International Relief Fund for the Afflicted and Needy-Canada (IRFAN-Canada), a registered charity under the Income Tax Act (ITA), stating that it has been suspended for one year beginning on April 13, 2010.

The notice stated in part that:

“...it remains our view that IRFAN-Canada has:

•failed to maintain books and records in Canada in accordance with subsection 230(2) of the ITA,
•failed to provide books and records for audit and examination in accordance with subsection 231.1(1) of the ITA, and
•failed to comply with a requirement to provide documents or information in accordance with subsection 231.2(1) of the ITA.”
A charity that has been suspended has no authority to issue donation receipts for income tax purposes for gifts it may receive during its suspension. Also, during the suspension, the charity is deemed not to be a qualified donee, prohibiting other registered charities from making gifts to it during that period.

Registered charities in Canada perform valuable work in our communities, and Canadians support this work in many ways. The CRA regulates charities through the ITA and is committed to ensuring that charities operate in compliance with the law. Where a registered charity is found not to comply with its legal requirements, the CRA may apply monetary penalties, suspend receipting privileges, or revoke the charity’s status under the ITA.

The notice of suspension and other letters relating to a suspension are available to the public on request by calling the CRA’s Charities Directorate at 1-800-267-2384.

More information about registered charities is available at http://www.cra.arc.gc.ca/charities

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Mark Blumberg is a lawyer at Blumberg Segal LLP in Toronto, Ontario.  To find out more about legal services that Blumbergs provides to Canadian charities and non-profits please visit http://www.canadiancharitylaw.ca or http://www.globalphilanthropy.ca  Mark can be contacted at .(JavaScript must be enabled to view this email address) or at 416-361-1982.

This article is for information purposes only. It is not intended to be legal advice. You should not act or abstain from acting based upon such information without first consulting a legal professional.

April 10, 2010

Canadian Charities Recently Revoked by the Charities Directorate of CRA for Cause 2010

I was recently wondering how many Canadian charities have recently lost their registered charity status for cause?  Also for what reasons did they lose their registered charitable status?  See my note
Canadian Charities Recently Revoked by CRA for Cause.

Here is a list of registered Canadian charities that lost their charitable status from January 1, 2009 to March 31, 2010.  This list covers a 15 month period.  The information is taken directly from the CRA’s publicly accessible database located at http://www.cra-arc.gc.ca/ebci/haip/srch/advancedsearch-eng.action

There were 49 charities that lost their status for cause during that period.  During that same period there were 660 who lost it for failure to file their T3010 return.  There were also 1299 voluntary revocations.  I was quite frankly surprised that only 49 charities lost their status over that 15 month period for cause. 

CRA has recently added to their database for some of the revoked for cause charities a summary of the reason the registered charity lost its status and in those cases I have pasted in that information.  About 24 of the 49 revoked charities have a summary.  In addition, I have placed the names of the directors contained in the last T3010 Registered Charity Information Return filing that had directors listed.

Canadian Charities Recently Revoked by CRA for Cause.

Mark Blumberg is a lawyer at Blumberg Segal LLP in Toronto, Ontario.  To find out more about legal services that Blumbergs provides to Canadian charities and non-profits please visit http://www.canadiancharitylaw.ca or http://www.globalphilanthropy.ca  Mark can be contacted at .(JavaScript must be enabled to view this email address) or at 416-361-1982.

This article is for information purposes only. It is not intended to be legal advice. You should not act or abstain from acting based upon such information without first consulting a legal professional.

 

Charges laid by CRA in Canadian inflated donation tax fraud investigation

Here is a copy of a press release from the Canada Revenue Agency entitled “Charges laid in donation tax fraud investigation”.  In the press release CRA discusses the charges it has laid against three people who allegedly issued donation receipts for more than the amount of the donation.  CRA noted that “The Income Tax Act permits registered charities to issue tax receipts only for the amounts actually donated. Schemes that promise a tax receipt in excess of what a donor gives are usually fraudulent. The CRA audits charities to put a stop to such schemes and intends to prosecute tax preparers, directors of charities, and donors who are found to be involved.”

Charges laid in donation tax fraud investigation

Victoria, British Columbia, April 8, 2010… Canada Revenue Agency (CRA) investigators have laid charges against Martin Danso-Dapaah, Carrie-Anne Danso-Dapaah and Michael Meszaros, all of Victoria, B.C., for offences relating to the alleged sale of more than $7.6 million in inflated charitable donation receipts. The alleged offences included donation receipts issued by CanAfrica International Foundation and Canadian Foundation for Child Development – all formerly registered charities.  The Danso-Dapaahs and Meszaros are alleged to have played various roles in the sale of charitable donation receipts to more than 450 individuals at 10 to17 per cent of their face value, creating a tax credit greater than the value of the purchase price.

Schemes involving false or inflated charitable donation receipts and tax preparer fraud are being investigated as part of Project Trident, a CRA-wide enforcement project that helps protect the tax base by pursuing key players in fraudulent tax schemes and reassessing related tax returns. Project Trident targets three types of fraud: identity theft, charities related fraud, and tax preparer fraud. For more information, visit http://www.cra.gc.ca/projecttrident.

The CRA is committed to ensuring all businesses have a level playing field and pursues individuals and businesses who deliberately attempt to evade taxes. “Schemes such as this cause taxes to be evaded, takes money away from the services that benefit all Canadians and undermines the important work of legitimate registered charities,” said Paul Brown, Assistant Director of Enforcement at the Vancouver Island Tax Services Office.

The CRA is committed to helping charities and donors understand their obligations under Canada’s tax laws. The Income Tax Act permits registered charities to issue tax receipts only for the amounts actually donated. Schemes that promise a tax receipt in excess of what a donor gives are usually fraudulent. The CRA audits charities to put a stop to such schemes and intends to prosecute tax preparers, directors of charities, and donors who are found to be involved.

Individuals who have participated in similar donation arrangements can still voluntarily correct their tax affairs.  Taxpayers will not be penalized or prosecuted if they make a valid disclosure before they become aware of any compliance action being initiated by the CRA against them. These taxpayers will only have to pay the taxes owing, plus interest. More information on the Voluntary Disclosures Program can be found on the CRA’s website at http://www.cra-arc.gc.ca/voluntarydisclosures .

The information in this news release is consistent with that found in the court records.

Further information on convictions can also be found in the Media room on the CRA website at
http://www.cra-arc.gc.ca/convictions .

- 30 -

For more information:
Dave Morgan
Communications Manager
604-587-2533

Transparency - What can the Charities Directorate of CRA disclose about registered charities?

The Income Tax Act (Canada) sets tremendous limits on the ability of CRA to disclose information about Canadian charities.  Essentially, the Income Tax Act in section 241 and its confidentiality provisions forbid CRA from disclosing any information about any registered charities either through informal request or a formal access-to-information request unless the information falls within certain narrow exceptions.  I will note below the provisions but I think that CRA should have greater flexibility to be able, especially in the few cases of major charity scams or tax avoidance schemes, to warn Canadians about any concerns that CRA has.  Unless a charity consents to disclosure (not likely), CRA now can only provide, after the charity has lost its registered status, either its “entirety of or any part of any letter sent by or on behalf of the Minister to the charity relating to the grounds for the revocation or annulment”.  By the time the charity has lost its registered charity status it could be years after CRA had significant concerns about the charity.   

Here is a CRA summary policy which discusses the effect of s. 241.

Summary Policy Date
June 9, 2003 (Revised September 13, 2005)

Reference Number
CSP - C12

Key Words
Confidentiality - Income Tax Act

Policy Statement
The confidentiality provisions of the Income Tax Act prevent the Canada Revenue Agency (the “CRA”) from discussing the affairs of a particular organization without the consent of an authorized representative.

Under the Act, the information contained in the public portion of a registered charity’s information return is available to the public. The CRA can also provide to any person the following information relating to a charity that at any time was a registered charity:

•a copy of the charity’s governing documents, including its statement of purpose;
•any information provided in prescribed form to the Minister by a charity in its application for registration as a charity under the Income Tax Act;
•the names of the persons who at any time were the charity’s directors/trustees and the periods during which they were its directors/trustees;
•a copy of the notification of the charity’s registration, including any conditions and warnings;
•if the registration of a charity has been revoked or annulled, a copy of the entirety of or any part of any letter sent by or on behalf of the Minister to the charity relating to the grounds for the revocation or annulment;
•financial statements required to be filed with an annual information return;
•a copy of the entirety of or any part of any letter or notice by the Minister to the charity relating to a suspension or an assessment of tax or penalty (other than the amount of a revocation tax); and
•an application by the charity and information filed in support of the application for special status or an exemption under the Act (e.g. permission to accumulate funds).
A list of currently registered charities, a list of newly registered charities and a list of recently revoked charities are available to the public on the CRA Charities Directorate Web site.

References
•Confidentiality, CIL-2000-011.
•Completing the Registered Charity Information Return, T4033B.
•Income Tax Act, R.S.C. 1985 (5th supp.) c. 1, ss. 149.1(15) and 241(3.2).

Here is part of S. 241 of the Income Tax Act:
Provision of information

241. (1) Except as authorized by this section, no official or other representative of a government entity shall

(a) knowingly provide, or knowingly allow to be provided, to any person any taxpayer information;

(b) knowingly allow any person to have access to any taxpayer information; or

(c) knowingly use any taxpayer information otherwise than in the course of the administration or enforcement of this Act, the Canada Pension Plan, the Unemployment Insurance Act or the Employment Insurance Act or for the purpose for which it was provided under this section.

Evidence relating to taxpayer information

(2) Notwithstanding any other Act of Parliament or other law, no official or other representative of a government entity shall be required, in connection with any legal proceedings, to give or produce evidence relating to any taxpayer information.

Communication where proceedings have been commenced

(3) Subsections 241(1) and 241(2) do not apply in respect of

(a) criminal proceedings, either by indictment or on summary conviction, that have been commenced by the laying of an information or the preferring of an indictment, under an Act of Parliament; or

(b) any legal proceedings relating to the administration or enforcement of this Act, the Canada Pension Plan, the Unemployment Insurance Act or the Employment Insurance Act or any other Act of Parliament or law of a province that provides for the imposition or collection of a tax or duty.

Circumstances involving danger

(3.1) The Minister may provide to appropriate persons any taxpayer information relating to imminent danger of death or physical injury to any individual.

Registered charities

(3.2) An official may provide to any person the following taxpayer information relating to another person that was at any time a registered charity (in this subsection referred to as the “charity”):

(a) a copy of the charity’s governing documents, including its statement of purpose;

(b) any information provided in prescribed form to the Minister by the charity on applying for registration under this Act;

(c) the names of the persons who at any time were the charity’s directors and the periods during which they were its directors;

(d) a copy of the notification of the charity’s registration, including any conditions and warnings;

(e) if the registration of the charity has been revoked or annulled, a copy of the entirety of or any part of any letter sent by or on behalf of the Minister to the charity relating to the grounds for the revocation or annulment;

(f) financial statements required to be filed with an information return referred to in subsection 149.1(14);

(g) a copy of the entirety of or any part of any letter or notice by the Minister to the charity relating to a suspension under section 188.2 or an assessment of tax or penalty under this Act (other than the amount of a liability under subsection 188(1.1)); and

(h) an application by the charity, and information filed in support of the application, for a designation, determination or decision by the Minister under subsection 149.1(6.3), (7), (8) or (13).

 

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Mark Blumberg is a lawyer at Blumberg Segal LLP in Toronto, Ontario.  To find out more about legal services that Blumbergs provides to Canadian charities and non-profits please visit http://www.canadiancharitylaw.ca or http://www.globalphilanthropy.ca  Mark can be contacted at .(JavaScript must be enabled to view this email address) or at 416-361-1982.

This article is for information purposes only. It is not intended to be legal advice. You should not act or abstain from acting based upon such information without first consulting a legal professional.

 

 

Contact Information for the Charities Directorate of the Canada Revenue Agency (CRA)

Here is the contact information for the Charities Directorate of the Canada Revenue Agency.

Contact information

The Charities Directorate Website:  http://www.cra-arc.gc.ca/chrts-gvng/chrts/menu-eng.html

Detailed Contact information:  http://www.cra-arc.gc.ca/chrts-gvng/chrts/cntct/menu-eng.html

Mail: Charities Directorate, Canada Revenue Agency, Ottawa ON K1A 0L5

Fax:
613-954-8037 (General)
613-954-2586 (Director General’s office)
613-948-1320 (Policy, Planning & Legislation)
613-952-6020 (Assessment & Determinations)
613-954-8037 (Client Services)
613-957-8925 (Monitoring)
613-946-2423 (Information Programs)

Telephone: 1-800-267-2384 (or 613-954-0410)

T3010B - CRA’s views on “What constitutes a completed annual filing?”

It is very important that Canadian registered charities file their T3010B Registered Charity Information Return.  This is supposed to be done within 6 months of the year end.  However, it is important not only that it is filed but also that it is accurate and complete.  In the Charities Directorate mailing called RC296E What’s the Scoop 2010 or the French version at RC296F En exclusivité 2010 Renseignements pour les organismes de bienfaisance enregistrés the CRA discusses what “What constitutes a completed annual filing?”

“What constitutes a completed annual filing?
The Income Tax Act requires a charity to file an information return each year. All charities with fiscal periods ending in 2009 and onward must submit:
■ Form T3010B, Registered Charity Information Return;
■ Form TF725, Registered Charity Basic Information Sheet;
■ Form T1235, Directors/Trustees and Like Officials Worksheet;
■ Form T1236, Qualified Donees Worksheet / Amounts Provided to Other Organizations (if applicable);
■ a copy of the charity’s financial statements;
■ Form T2081, Excess Corporate Holdings Worksheet for Private Foundations (if applicable); and
■ Form RC232-WS, Director/Officer Worksheet and Ontario Corporations Information Act Annual Return or Form RC232, Ontario Corporations Information Act Annual Return (if applicable).

Note: Failure to include financial statements with a charity’s return can lead to revocation of its registration.”

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Mark Blumberg is a lawyer at Blumberg Segal LLP in Toronto, Ontario.  To find out more about legal services that Blumbergs provides to Canadian charities and non-profits please visit http://www.canadiancharitylaw.ca or http://www.globalphilanthropy.ca  Mark can be contacted at .(JavaScript must be enabled to view this email address) or at 416-361-1982.

This article is for information purposes only. It is not intended to be legal advice. You should not act or abstain from acting based upon such information without first consulting a legal professional.

 

 

T3010B - Common mistakes with Form RC232-WS or Form RC232 - director worksheets for Ontario charity

In this piece CRA identifies certain common mistakes in how registered Canadian charities that were incorporated in Ontario and subject to the Ontario Corporations Act file Form RC232-WS or Form RC232.  This directors/officer worksheet is filed with their T3010B Registered Charity Information Return.

This is another note that we learn from the Charities Directorate mailing called RC296E What’s the Scoop 2010 or the French version at RC296F En exclusivité 2010 Renseignements pour les organismes de bienfaisance enregistrés

“Filing reminders for Form RC232-WS, Director/Officer Worksheet and Ontario Corporations Information Act Annual Return, and Form RC232, Ontario Corporations Information Act Annual Return

Since January 2009, registered charities incorporated in Ontario and subject to the Ontario Corporations Act may file Form RC232-WS or Form RC232 with their T3010 Registered Charity Information Return. Over the past year, we have been reviewing the submitted RC232-WS and RC232 and have identified the following common filing errors. It is a charity’s responsibility to provide complete and accurate information when filing its annual return. Failure to provide this information may result in follow-up
action from either the Canada Revenue Agency or the Ministry of Government Services for the Province of Ontario.

1. Form RC232-WS, Part 8 – not completed

Form RC232-WS, Director/Officer Worksheet and Ontario Corporations Information Act Annual Return, is a blended form that collects corporate information for the Province of Ontario and the CRA under the authority of the Corporations Information Act and the Income Tax Act. Part 8 of Form RC232-WS collects director/officer information for CRA purposes only. The information is confidential and will not be transmitted to the Government of Ontario. To fulfill your filing obligation with the CRA, Part 8 must be completed.

2. Forms RC232-WS and RC232 – filed without Form T3010B

The CRA will accept forms RC232-WS and RC232 only if they are filed with a Form T3010B, Registered Charity Information Return. If a charity wants to change the information for its directors or corporate
officers at another time during the year, it must contact both the CRA and ServiceOntario. 

3. Forms RC232-WS and RC232 – street name in Part 7 not completed

When completing the address information note that the Street name, Rural Route, P.O. Box, City, and Country are mandatory pieces of information for the address fields. In particular, when completing
address information for a Director or Officer in Part 7, remember to provide the Street name, Rural Route or P.O. Box in the “Street Name” field 731.

4. Forms RC232-WS and RC232 – “Elected/Appointed” is left blank when ceasing the name of a director/officer in Part 7

When removing the name of a director or officer, a charity must enter the date elected/appointed and a cease date for all the director/officer positions shown for that individual.

5. Form RC232-WS – changes to the name of a director/officer are not correctly done

When changing the name of a director or officer, do not white out, scratch the name out, or write “Delete” over the information in Part 7. The way to change the name of a director or officer is as
follows:

1. Enter a cease date for all director/officer positions shown for that individual.
2. Photocopy the blank page included with Form RC232-WS for each individual for which changes are being made.
3. Complete a blank Part 7 and Part 8 with the new director/officer information.”

New CRA Charities Directorate electronic publication to replace Registered Charities Newsletter

The CRA has announced that they will be producing an electronic publication to replace Registered Charities Newsletter.  It will be called “Charities Connection”

This is another piece of information that we learn from the Charities Directorate mailing called RC296E What’s the Scoop 2010 or the French version at RC296F En exclusivité 2010 Renseignements pour les organismes de bienfaisance enregistrés

:“New electronic publication to replace Registered Charities Newsletter
In April 2010, the Charities Directorate will introduce a new electronic publication that will replace the Registered Charities Newsletter. This new publication, called Charities Connection, will be shorter (two to
three pages) and will be posted to the CRA Charities and Giving Web pages about 8 to 12 times a year.

The Registered Charities Newsletter it will be replacing was only published twice a year. When the new Charities Connection is posted to the Charities and Giving Web pages, an email will be sent to notify all subscribers to the Charities and Giving – What’s New electronic mailing list.

Our goal is to provide registered charities with timely, up-to-date information on technical issues, new or enhanced policies, new initiatives, and reminders about important information.
Charities Connection will be published on a trial basis and, if successful, it will permanently replace the current newsletter format. If you have questions or comments on this new publication, please email them to .(JavaScript must be enabled to view this email address). “

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Mark Blumberg is a lawyer at Blumberg Segal LLP in Toronto, Ontario.  To find out more about legal services that Blumbergs provides to Canadian charities and non-profits please visit http://www.canadiancharitylaw.ca or http://www.globalphilanthropy.ca  Mark can be contacted at .(JavaScript must be enabled to view this email address) or at 416-361-1982.

This article is for information purposes only. It is not intended to be legal advice. You should not act or abstain from acting based upon such information without first consulting a legal professional.

 

Improved turnaround time for Canadian charity applications at CRA with backlog removed

According to CRA “Thanks to changes in processes, more resources, and the dedication of staff and management in the Directorate’s Assessment, Determinations and Monitoring Division, it now takes significantly less time to process applications for registration as a Canadian charity.”  More complicated applications that I file that used to take 6-9 months to now being responded to in 6-9 weeks - it is an amazing improvement which is welcomed by all those involved with applications for charity status.  On a sad note after four years in the Charities Directorate, David Moore, the Director of the Determinations Division, and instrumental in reducing the backlog has moved to the Treasury Board Secretariat (TBS) from the Charities Directorate. David Moore was responsible for establishing the Client Interface and Service Division and led the work on the Small and Rural Charities Initiative which was and continues to be very successful in making CRA more responsive to the needs of small and rural charities. David will be missed. I understand that Linda Desrochers, will become the interim Director of the Determinations Section.

This is another piece of information that we learn from the Charities Directorate mailing called RC296E What’s the Scoop 2010 or the French version at RC296F En exclusivité 2010 Renseignements pour les organismes de bienfaisance enregistrés

“Improved turnaround time for applications
One of the main functions of the Charities Directorate is to determine whether an organization is eligible to be registered as a charity. Registration not only provides an organization with tax privileges, but the registration process also plays a role in ensuring the integrity of the charitable sector in Canada. The time
it takes to register an organization depends on the completeness and the complexity of the information provided in its application.  Thanks to changes in processes, more resources, and the dedication of staff and management in the Directorate’s Assessment, Determinations and Monitoring Division, it now takes significantly less time to process applications for registration as a Canadian charity.

Reminder
For the timely processing of an application for registration or re-registration, make sure you give a complete answer to every question on Form T2050, Application to Register a Charity Under the Income Tax Act, and attach all necessary documents. For more information about registering a charity, visit our
“Applying for registration” Web pages at http://www.cra-arc.gc.ca/chrts-gvng/chrts/pplyng/menu-eng.html.”

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Mark Blumberg is a lawyer at Blumberg Segal LLP in Toronto, Ontario.  To find out more about legal services that Blumbergs provides to Canadian charities and non-profits please visit http://www.canadiancharitylaw.ca or http://www.globalphilanthropy.ca  Mark can be contacted at .(JavaScript must be enabled to view this email address) or at 416-361-1982.

This article is for information purposes only. It is not intended to be legal advice. You should not act or abstain from acting based upon such information without first consulting a legal professional.

 

April 09, 2010

Mark’s mini poll at AFP Conference on CRA’s Fundraising Guidance

In December 2009 I delivered a presentation on “CRA’s Fundraising Guidelines –Legal, Ethical and Practical Issues” to the Association of Fundraising Professionals (AFP) GTA Congress 2009.  Prior to giving the presentation I handed out a mini poll to the 100 or so attendees at my session and about 47 of them returned the poll to me.  The attendees were almost all fundraisers and probably the fundraisers who had the greatest interest in the topic.  This is certainly not scientific. 

Mark Blumberg’s mini poll - December 1, 2009

Question #1:  Does fundraising take up a majority of your role with charities?
Yes: 35
No: 11
Both: 1

Question #2:  Have you read the CRA fundraising guidance?
Yes: 30
No: 17

Question #3:  Do you think that it is desirable to have some regulation of fundraising in Canada?
Yes: 46
No: 0
Unanswered: 1

Question #4:  What part of the CRA fundraising guidance do you find most difficult to understand?

- Dealing with fair market value
- A lot of the technical terms and vocabulary is daunting
- Incentives for giving donations
- Details surrounding the fund disbursement changes
- Too confusing entirely - especially the COFR, where’s the template?
- Split receipting
- Allocation of expenditures
- Tax receipting of in-kind donations, tax receipting of special event sponsorship and ticket purchase, tax receipting of donated professional services
- All of it - use the 1-800 number when planning virtually everything
- Tax receipting
- What qualifies as non fundraising expense
- The 80/20 rule - impossible for small charities to achieve notwithstanding integrity, excellent board and staff
- Cost per dollar guidelines as they did not make things clearer and likely further confuse things for the general public
- Definition of FR costs and cost allocation
- The four part test
- Advocacy
- Quotas - qualifications
- Fundraising as a non-charitable activity; you have to put on events and do activities to engage people to give to your charity; have to raise funds to solicit donations
- Allocation
- Allocation
- Calculation
- Having everyone of the organization (volunteers, board, employees) to follow the rules
- Fundraising ratio
- Complexity of the guidance

Question #5:  What part of the fundraising guidance will be the greatest challenge to apply in the organization(s) that you are involved with?

- The various calculations surrounding cost/dollar raised details
- It will be important for “fundraising” to be way more involved in CRA filing
- Split receipting
- Educating donors that fundraising costs are essential to doing a good fundraising job
- Tax receipting of in-kind donations, tax receipting of special event sponsorship and ticket purchase, tax receipting of donated professional services
- What is and is not applicable stuff
- Stuff regarding new guidelines for stocks, etc…
- Receipting around gifts
- Gift-in-kind (types)
- Convincing accountants to be more flexible
- The 80/20 rule - impossible for small charities to achieve notwithstanding integrity, excellent board and staff
- None for us, have low overhead and strong ethics; just the ever increasing administrative burden for small shops
- Fundraising cost ratios
- Starting a business
- Segregating personnel time in fundraising vs. charitable activities as we all do both; moving in and out of activities and standard hours and solicitation all day long
- T3010/allocation - having finance people understand
- That is presumes that one size fits all

Question #6:  What part of the fundraising guidance, if any, is most useful?

- Great reference if you have specific questions
- CRA bulletins
- Setting a standard that will be strictly followed for all charities, making charities more credible in the public eye
- Easily understood parts that we can use to explain rules to donors who make illegal demands
- Always good to have guidelines - it definitely is great to show your supporters that you are following the guidelines
- For the sector, it should increase accountability, transparency, etc…
- None
- Basics - charity giving money to another
- We are a college foundation raising funds exclusively for the college; fundraising is an activity - not the main purpose
- Test for allocation
- It allows us to educate volunteers about the ethics and accountability
- Makes misconduct explicit