As of November 14, 2018, CRA will no longer send out the peel and stick barcode labels with the T3010 annual information return package. These stickers were on the back of Form TF725, Registered Charity Basic Information Sheet. Charities will continue to receive Form TF725, on which they will be able to verify and make changes to their telephone number, fax number, email, website address and/or mailing address.
The barcodes contained both the charity’s BN/registration number and the charity’s fiscal year end date. Both of these numbers appear on the front of the T3010 form, so there will not be a big impact to the T3010 form itself. However, both the T1235 – Directors/Trustees and Like Officials Worksheet and the T1236 – Qualified Donees Worksheet, which must be submitted with the T3010 if applicable to the charity, do not contain a space for the Charity’s information, including charity name, BN/registration number and fiscal year end date.
If these forms are mistakenly separated from the T3010, it would be very hard to link these forms back to the right charity. To ensure that these forms are not misplaced, and that CRA does not think that the charity has submitted an incomplete return (which is grounds for revocation of status), it would be a good idea for charities to manual write in the charity’s BN/registration number at the top of each of these forms. Alternatively, some charities prefer to complete these forms using their own spreadsheets or tables. Charities are advised to have their details at the top of any such attachments. However, any charity that makes its own tables or spreadsheets should make sure that they have the exact same information as CRA’s form. Otherwise the filing will be incomplete.
This change has come in anticipation of CRA’s new Charities IT Modernization Project (CHAMP), which is set to launch in June 2019. Through this new program, registered charities will have the option of filing their T3010 online and CRA is making some changes to the paper T3010 to harmonize it with the online platform.
All charities must complete their T3010 filings, whether or not they have been active during the year, and charities can have their status revoked if they do not make their filing. In light of the CHAMP launch, charities should be aware that there may be more changes to the T3010 and the supplemental forms. Charities should always make sure that they are using the correct form for the fiscal year and complying with CRA’s Guidance on the T3010.
For some larger organizations we review T3010s prior to filing. It is easier to submit the form accurately than to make changes later. The T3010 is one of the main ways that CRA determines whether it will audit a registered charity and if you have red flags in your T3010 it can increase the likelihood of audit significantly.
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Mark Blumberg is a partner at the law firm of Blumberg Segal LLP in Toronto and works almost exclusively in the areas of non-profit and charity law.