The CRA has revoked the Canadian Friends of Pearl Children for involvement with what CRA would term an abusive charity gifting tax scheme.
Here is the CRA press release:
http://news.gc.ca/web/article-en.do?nid=1002989
The Canada Revenue Agency revokes the registration of the Canadian Friends of Pearl Children
July 17, 2015 Ottawa, ON Canada Revenue Agency
The Canada Revenue Agency (CRA) will revoke the registration of the Canadian Friends of Pearl Children, a charity based in Ottawa, Ontario, effective July 18, 2015. The notice of revocation has been published in the Canada Gazette.
On June 2, 2015, the CRA issued a notice of intention to revoke the registration of the Canadian Friends of Pearl Children as a charity, in accordance with subsection 168(1) of the Income Tax Act. The letter stated, in part, that:
“The audit by the Canada Revenue Agency (CRA) has revealed that the Organization operated primarily for the non-charitable purpose of furthering a tax shelter donation arrangement, the Mission Life Financial Inc. Canadian Relief Program. The Organization agreed to accept alleged gifts of property from participants and to act as a receipting agent for this donation arrangement. For the period June 1, 2008 to December 31, 2012, the Organization improperly issued receipts totalling over $167 million for purported donations of cash and pharmaceuticals, which were not legitimate gifts. Of the over $4 million in cash contributions it received, the Organization paid $3.19 million to the promoters of the tax shelter. With the over $163 million worth of tax receipts issued for the gifts of pharmaceuticals, the CRA determined that the Organization significantly over-reported the value of the alleged property, resulting in grossly inflated tax receipts to participants. Further, the Organization failed to demonstrate that it had actually received the tax-receipted pharmaceuticals or that it had carried out any charitable activities using these pharmaceuticals.”
Registered charities perform valuable work in our communities, and Canadians support this work in many ways. The CRA regulates these organizations through the Income Tax Act and is committed to ensuring that they operate in compliance with the law. When a registered charity is found not to comply with its legal obligations, the CRA may revoke its registration under the Income Tax Act.
Registered charities receive generous tax incentives under the Income Tax Act including the ability to issue official donation receipts. To maintain this privilege, charities must continue to meet all the requirements of the Act.
The CRA is committed to preserving the integrity of Canada's tax system. The CRA audits every gifting tax shelter that offers official donation receipts in excess of the value of any property donated.
An organization that has had its registration as a charity revoked can no longer issue donation receipts for income tax purposes and is no longer a qualified donee under the Income Tax Act. The organization is no longer exempt from income tax, unless it qualifies as a non-profit organization, and it may be subject to a tax equal to the full value of its remaining assets.
For more information about the registration of Canadian charities or to find out more about a registered charity, go to the CRA's Charities and Giving Web page.
Quick facts
As of December 31, 2014, there were 86,193 registered charities across Canada.
Canadian registered charities issued receipts worth more than $14.5 billion in 2013.
In the 2013-14 fiscal year (April 1 to March 31), the CRA's Charities Directorate completed 845 audits of registered charities chosen using a variety of methods, including random selection, follow-up on possible non-compliance or complaints, and based on a review of annual information returns; during that same period, 23 charities had their registered status revoked by the CRA as a result of an audit.
As of March 31st, 2014, the CRA reassessed more than 190,000 taxpayer returns, denying in excess of $6.3 billion in donation claims mostly due to tax shelter gifting arrangements.
A copy of the notice of intention to revoke and other letters relating to the grounds for revocation are available to the public on request, in the language they were originally written, by calling 1-800-267-2384 FREE.Related Products
Canada Revenue Charities Listings: http://www.cra-arc.gc.ca/chrts-gvng/lstngs/menu-eng.html
Charities Media Kit: http://www.cra-arc.gc.ca/chrts-gvng/md-kt/menu-eng.html– 30 –
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Contacts
Philippe Brideau
Media Relations
Canada Revenue Agency
613-941-6269
According the CRA website the last listed directors were:
Directors / Trustees and Like Officials – Canadian Friends of Pearl Children
3 Directors/Trustees and Like Officials
1
Last name:Rotenberg
First name: Dvora
Initial/Middle name:
Director/Trustee/Like Officials Term:
Start Date:
End Date:
Position: Managing Director
At arm's length with other Directors, etc.?: Yes2
Last name:Rosenberg
First name: David
Initial/Middle name:
Director/Trustee/Like Officials Term:
Start Date:
End Date:
Position: Ottawa
At arm's length with other Directors, etc.?: Yes3
Last name:Pasternak
First name: Jay
Initial/Middle name:
Director/Trustee/Like Officials Term:
Start Date:
End Date:
Position: Director
At arm's length with other Directors, etc.?: Yes
Here is the Industry Canada search for the corporation:
Federal Corporation Information – 4474856
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Corporation Number
4474856
Business Number (BN)
805697810RC0001
Governing Legislation
Canada Not-for-profit Corporations Act – 2015-07-14
Corporate Name
CANADIAN FRIENDS OF PEARL CHILDREN
Status
ActiveRegistered Office Address
226 MACLAREN STREET
OTTAWA ON K2P 0L6
Canada
Note:Active NFP Act corporations are required to update this information. Changes are only legally effective when filed with Corporations Canada. A corporation key is required.Directors
Minimum
3
Maximum
9
DirectorsDEUS LUKWATA
21-B POPLAR STREET
OTTAWA ON K1R 6V1
Canada
CRYSTAL DAWN SKIEHAR
253 ST. JACQUES STREET
OTTAWA ON K1L 5G6
Canada
DVORA ROTENBERG
949 CAVAN STREET
OTTAWA ON K1Z 5T1
CanadaNote:Active NFP Act corporations are required to update director information (names, addresses, etc.) within 15 days of any change. Acorporation key is required.
Annual Filings
Anniversary Date (MM-DD)
07-14
Date of Last Annual Meeting
Not Available
Annual Filing Period (MM-DD)
07-14 to 09-12
Type of Corporation
Not Available
Status of Annual Filings2016 – Not due
Corporate History
Corporate Name History
2008-04-11 to 2015-07-14
CANADIAN FRIENDS OF PEARL CHILDREN
2015-07-14 to Present
CANADIAN FRIENDS OF PEARL CHILDRENCertificates and Filings
Certificate of Continuance
2015-07-14
Previous jurisdiction: Canada Corporations Act – Part II (CCA-II)
By-laws
Received on 2015-07-20
Here is a link to the Canada Gazette with the notice.
In a CBC article it notes '”Rotenberg said she plans to appeal the CRA decision. She continues to operate a sister charity called “Lifecan International.” You can read about it at https://www.facebook.com/lifecaninternational It notes 'Please “LIKE” our page. We will be taking over all projects of Canadian Friends of Pearl Children in the next few months. Website will be posted soon. Thanks!!”
Here is information from Industry Canada on Lifecan. I am not sure if it is the same as “Lifecan International” but it appears to be.:
Federal Corporation Information – 4406001
Glossary of Terms used on this page
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Corporation Number
4406001
Business Number (BN)
826305567RC0001
Governing Legislation
Canada Not-for-profit Corporations Act – 2015-02-26
Corporate Name
LIFECAN
Status
ActiveRegistered Office Address
949 CAVAN STREET
OTTAWA ON K1Z 5T1
Canada
Note:Active NFP Act corporations are required to update this information. Changes are only legally effective when filed with Corporations Canada. A corporation key is required.Directors
Minimum
3
Maximum
5
DirectorsDVORA ROTENBERG
949 CAVAN STREET
OTTAWA ON K1Z 5T1
Canada
LOUISE MENARD
1832 NORTHLANDS DRIVE
ORLEANS ON K4A 3S2
Canada
DEUS LUKWATA
21B POPLAR STREET
OTTAWA ON K1R 6V1
CanadaNote:Active NFP Act corporations are required to update director information (names, addresses, etc.) within 15 days of any change. Acorporation key is required.
Annual Filings
Anniversary Date (MM-DD)
02-26
Date of Last Annual Meeting
Not Available
Annual Filing Period (MM-DD)
02-26 to 04-27
Type of Corporation
Not Available
Status of Annual Filings2016 – Not due
Corporate History
Corporate Name History
2007-01-11 to 2012-06-21
Future Generations Canada
2012-06-21 to 2015-02-26
LIFECAN
2015-02-26 to Present
LIFECAN
Here is a link to the CRA information on Lifecan:
http://www.charityfocus.ca/EN/Pages/CharitySummary.aspx?CharityID=826305567RR0001
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