The Not-for-Profit Organizations Task Force of the Risk Oversight and Governance Board of the Canadian Institute of Chartered Accountants has released a submission on Bill C-470.  Here is the full submission and also below are the summary and conclusion.  The moral of the story I think is that there is nothing redeeming about this flawed piece of legislation.  Can someone please show me one organization that knows anything about the charitable sector who supports this nonsense.

We are concerned that Bill C-470 was proposed without public consultation and feel that the Bill has the potential for significant negative impacts on charities in Canada. While we agree that transparency and accountability of charities is of critical importance and benefits both the public and the charities themselves, we do not believe that the proposed amendments to the Income Tax Act will lead to improvements in this area.

In conclusion, we feel that the amendments proposed in Bill C-470 would not have the desired effect of enhancing accountability and transparency in the charitable sector, and would be likely to have significant negative impacts on the sector. We recommend that the Bill not be enacted.