Here is the Blumbergs’ Submission to the House of Commons Standing Committee on Finance for the Pre-Budget Consultations in Advance of the Upcoming 2022 Federal Budget.  We offer 11 recommendations namely the following:


List of Recommendations

Primary Recommendations

  • Recommendation 1: That the Federal government amend Section 241 of the Income Tax Act in order to allow the CRA to disclose serious non-compliance with legal requirements by a registered charity, Registered Canadian Amateur Athletic Associations or certain other qualified donees.
  • Recommendation 2: That the Federal government amend Section 241 of the Income Tax Act in order to allow the CRA to disclose to the public information contained on the T1044 Non-Profit Organization (NPO) Information Return.

Secondary Recommendations

  • Recommendation 3: That the Federal government increase the disbursement quota payout from the current 3.5% to 10% in line with other groups requesting this improvement.
  • Recommendation 4: That the Federal government ensure that each donor advised fund is required to disburse a certain percentage per year per fund.
  • Recommendation 5: That the Federal government roll out additional educational programs to assist Canadian charities and non-profits understand their compliance obligations.
  • Recommendation 6: That the Federal government reinstate the Charities Partnership Outreach Program, or create a similar program, which provides funds to Canadian charities to fund educational initiatives within the sector to increase compliance.
  • Recommendation 7: That the Federal government require charities to demonstrate annually in their reporting that they actually have a “public benefit”, rather than this being assumed.
  • Recommendation 8: That the Federal government consider a system where the ability to issue tax receipts is not based on being a “registered charity” but rather a narrower category of deductible gift recipients as is currently in Australia.
  • Recommendation 9: That the Federal government establish a unit within the RCMP, or other police force, tasked with the responsibility of reviewing complicated abusive charity schemes that provide inappropriate official donation receipts or inappropriate private benefits.
  • Recommendation 10: That the Federal government providing funding to CRA to improve the transparency of the T3010 Registered Charity Information Return.
  • Recommendation 11: That the oversight of funding by charities of non-qualified donees is enhanced and the attempts to remove the requirement for structured arrangements be opposed.