The Trinity Global Support Foundation was recently revoked.   It received some media attention because of the involvement of the former mayor of London, Ontario in the charity.  Here are the letters from CRA explaining the detailed reasons for revocation of Trinity Global Support Foundation.  We blogged on this charity before at “CRA revokes Trinity Global Support Foundation as a charity” and “FCA case on Trinity Global Support Foundation – CRA wins again

The CRA notes:


Our audit revealed that the Organization devoted a significant portion of its resources to the promotion of the Mission Life Financial Inc, and Canadians Care donation arrangements. As a result of its participation in these arrangements, between June 1, 2007 and May 31, 2010, the Organization reportedly received nearly $25 million in cash and in-kind property.  With respect to the Mission Life Financial Inc., a registered tax shelter, the Organization issued tax receipts exceeding $1.13 million for cash contributions and $16 million for pharmaceuticals. Of the cash contributions received, the Organization paid nearly $1 .03 million to the promoters of the tax shelter and to the Organization's directors or related parties. It is our position the Organization issued the tax receipts improperly, particularly given our finding that the $16 million recorded for the pharmaceuticals were grossly inflated. As a result, we conclude neither contribution qualifies as gifts at law. 

With respect to the Canadians Care promoted donation arrangement, the Organization issued tax receipts exceeding $7.8 million for leveraged cash contributions. The Organization invested over $7 million into investments held by corporations related to its directors and.also related to the donation arrangement. These funds were subsequently lost due to the actions of those corporations. The Organization was also found to have improperly paid over $865,000 to individuals and corporations related to the Organization's directors.

Our audit has also revealed insufficient separation between the Organization's operations and the personal business and financial interests of those responsible for its operation. In particular, the Organization has entered into collusive contractual arrangements with directors and related parties, which resulted in/ substantially all of the actual cash received being diverted into the hands of the promoters and related companies rather than used for charitable purposes.

It is our position that the Organization has operated for the non-charitable purpose of promoting gifting donation arrangements and for the private benefit of the gifting donation arrangement promoters. The Organization also invested in non-qualified investments; gifted to non-qualified donees; issued receipts for transactions that do not qualify as gifts; issued receipts otherwise than in accordance with the Act and its Regulations; failed to maintain adequate books and records; and failed to file an accurate Form T3010, Registered Charity Information Return. For all of these reasons, and for each of these reasons alone, it is the position of the CRA that the Organization's registration should be revoked.

The CRA had numerous concerns including that the charity operated outside its object, it was mainly promoting a registered tax shelter arrangement, it made gifts to non-qualified donees, it had high fundraising costs, and provided too much personal benefit to certain related persons. It is interesting that they note “Although the 2011 fiscal was not included in the audit period, the Organization provided CRA with a donation summary for this period showing $68 million receipted as a result of its participation and promotion of the Mission Life Financial Inc. tax shelter and we have discovered the Organization also entered into a contract with Global Learning Gifting Initiative (GLGI), another registered tax shelter.”