Here is the Notice of Ways and Means Motion to introduce An Act respecting certain measures in response to COVID-19 that is available on the Department of Finance website.

It covers many issues relating to the COVID-19 crisis.

One item is that both registered charities and non-profits are able to claim a partial wage subsidy with certain restrictions.

In terms of the non-profits it refers to “(iv) a person exempt from tax under Part I because of paragraph 149(1)(l)” which is what is colloquially referred to as a non-profit organization that are not registered charities.  Many groups that are not registered charities are going to assume that they are an organization under paragraph 149(1)(l) and apply for the subsidy.  But are they really a non-profit that meets the requirements of paragraph 149(1)(l)?   Sorry to be raising this issue but this is one of the problems when you have a 1917 definition and no one has thought it important enough at Finance to update it.   See the NPORIP report for some of the issues.

If you are a section 149(1)(l) organization remitting less funds from the income tax portion of remittances as a result of the wage subsidy hopefully you have also done in the past your necessary filings such as a corporation filing a T2 and certain 149(1)(l) groups filing the T1044.  In other words, if you are taking advantage of this benefit as a paragraph 149(1)(l) organization hopefully your filings are up-to-date and you meet the other requirements for being a paragraph 149(1)(l) organization.   You may have to report to CRA ultimately relating to books and records.

There are many organizations that were incorporated as non-profits and consider themselves to be non-profits but in fact, they don’t meet all the requirements for a section 149(1)(l) organization.