Some historical CRA letters when revocation of charity status

For a number of years we have been providing the public with copies of CRA revocation letters.  These letters set out the CRA reasons for revocation of charitable status when CRA is alleging cause.  We recently requested from CRA some of the older revocation letters and we have posted them below.  It is interesting to see the difference between the current reasons for revocation and those from quite a few years ago. 

CRA is only allowed to release very limited information on a deregistered charity such as these letters, and only after deregistration.  CRA is generally not allowed to release letters from the charity to CRA, although you can sometimes obtain those documents by requesting them from the former charity.  If anyone has further information on these charities let me know.  Because CRA alleges in a letter a particular set of facts does not make it necessarily completely correct.

There have been about 50 or so cases in the Federal Court of Appeal with charities challenging the CRA revocations.  Although sometimes the court will disagree with some of the grounds I am not aware of any cases in the last decade of the Federal Court of Appeal overturning the revocations of CRA. 

Why should people care about revocations of charities?  The ability of CRA to revoke the registration of a registered charity can have significant impact on a charity and the charitable sector is an important part of our society and economy.  Why CRA would revoke a charity and explanations given are important.  It helps charities understand compliance issues.  It also allows the public to understand whether CRA is acting reasonably in the matter.  Here is a list of some of the CRA letters and in square brackets are the approximate date and the reasons for revocation and/or subject matter discussed in the letters.

• Adzena Fund Canada [2007 -retraction of compliance agreement, gifts in kind receipting, books and record]
• CanAfrica International Foundation [2007 – Books and Records, large scale receipting fraud, gifts in kind, Disbursement quota, non-charitable use of resources, payments to directors, improperly completed T3010]
• Greatwise Charity Fund [2007 – donations to “non-qualified donees” and lack of control over foreign activities, concern over loans, inadequate books and records]
• Holy Spirit Trinity Church of God Ijo Emi Mimo Ti Olorun Meta Lokan Alavura [2007 -books and records, altered invoices, receipting concerns, unreported donation revenue]
• Great Lakes Gospel Assembly [2007 – concern over foreign activities]
• Envision Global Charity [2007- foreign activities (Cuba), books and records, T3010. non-arms length people identified as arms length, valuation of pharmaceuticals, receipting, lack of internal controls, benefits to directors, whether compensation of directors is allowable]
• True Faith Church International  [2007- books and records, donation receipts, control over donation receipts, foreign activities, incorrectly filed T3010]
• Christ Ascension Church of Canada  [2007 -books and records, foreign activities, official donation receipts, incorrectly filed T3010]
• North America Missing Children Association Incorporated  [2007 – Books and Records, T4s, Vehicle Expenses, fundraising expenses and being fundraising conduit, official donation receipts, delinquent filing of T3010]   
• Holy Grounds Ministry International Inc.  [2004- failure to provide books and records]
• Exdeltra Inc. [2006]
• Gods Army Ministries [2006 -objects and new activities, inadequate books and records, official donation receipts, remuneration and benefits reporting]
• Maison daccueil lestime [2006]
• Fondation Ex-Voto – Ex-Voto Foundation [2006]
• Can-Afri Poverty Relief Organization  [2007 – no response to CRA letters]
• Meoroth [2006 – whether CRA will accept voluntary revocation, books and records, official donation receipts, involvement with donation arrangement “Canadian Humanitarian Trust”, valuation of pharmaceuticals, issuance of T4s]
• Centre universitaire de recherches internationales [2006]
• Miftahul-Uloom Canada [2007 – Books and Records, Objects and activities, not responding to CRA questions, radio programs, accepting time share units and building project]
• Canadian Literacy Enhancement Society [2007 – tax shelter arrangement, potentially false statement on charity application, self study not necessarily education, return of gift, gift to non-qualified donee, books and records, control and content of receipts, T3010 Filing ]
• Corban Foundation.pdf [1997- issuance of receipts, payment of tuition for students attending Christian schools, commission fundraising and private benefit]
• Jesus Inner-Healing Ministries Foundation Limited [1996 – receipting, T3010, failure to file financial statements, change in fiscal year without authorization from Revenue Canada, foreign activities]
• Babbar Khalsa Society  [1996 – discussion of objects that were political prior to registration, books and records, disbursement quota, receipting, lack of internal controls, failure to disclose information during audit, political activities]
• Greenpeace Canada Charitable Foundation  [1994 – gifts to non-qualified donees, lack of direction and control over funds provided to another organization, loans to a non-qualified donee, excessive political activities, disbursement quota, issuance of receipts when significant advantage received]
• Canadian Scholarship Trust General Fund  [1998 – scholarships and lack of public benefit, errors in T3010, receipts not including full name]
• The Lord’s Evangelical Church of Deliverance   [2003 – books and records, receipting, incorrect T4s, loan to person to purchase house, disbursement quota shortfall, foreign activities]
• Advance Academic College – [1997 – disbursement quota, receipting including gifts for services and personal benefits, T3010, failure to maintain adequate books and records]
• Jewish War Veterans of Canada National Command   [2004- lack mandatory information on receipts, receipts for fundraising dinners and sponsorship, T3010 mistakes, late filing of T3010, lack of direction and control over funds provided to non-qualified donees] 
• Je Maintiendrai Home Society [2003 -Concern about wording in objects, housing for low income and aged and necessary application process not followed, low cost housing and poverty line, non-related business activities, municipal requirements vs. CRA requirements]
• Parkinsons Support and Research Society  [2003 – Books and records, lack of devotion of resources to charitable activities, high fundraising costs, personal benefits, T4s, percentage compensation of fundraisers, deviation between charity application versus actual fundraising activities, lack of provision of governing documents to CRA ]
• Keys Please II! Designated Driving Foundation [2004 – books and records, T3010]
• Ordre Antonien Libanais [1996]
• Special Assistance Services Search and Rescue Association Canada [1998 – failure to file T3010, inaccuracies in the T3010, failing to meet disbursement quota]
• Zionist Organization of Canada Charitable Fund  [1995 – public policy, gift to qualified donees, foreign activities]
• The Christmas Gift Foundation [1994 – fundraising, T3010, disbursement quota]
• The AIDS Society for Children [1997 – high fundraising costs, benefits to members, books and records, T3010, receipts, salaries]
• Secours aux enfants du tiers-monde de Colombie  [1995]
• Logement occupe [1994]
• Les Services Partage Sans Prejuge [1996]
• La Croix brisee du Canada   [1996]
• God Has Spoken Ministries  [1995 – official donation receipts, gifting to non-qualified donees, foreign activities and missionaries, T3010, books and records]
• Fondation L’Astre [1997]
• Donelian Museum of Oriental Art [official donation receipts and fair market value, date of receipts]
• A.B.L.E. Association for the Betterment of Literacy and Education [1997 -official donation receipts and tax scheme involving loans and purchase of insurance, books and records, T3010]
• The Rafael Levin Fund – Hachnosas Kallah Fund  [2000 – scope of charity, issuing official donation receipts, directed donations, not complying with objects, inadequate books and records]
• The Meser Charitable Foundation  [2006 – Foreign activities, direction and control, books and records, Educational financial assistance to private group related to donors, personal benefits]
• Sunshine Coast Wildlife Rehabilitation Centre [2007- benefit to director (taking 2 bequests made to the charity), books and records, disbursement quota, failure to file T3010, donation receipts]
• Jeunesse Sans Faim [2006]
• Senior Assist Association of Canada  [2006 – fundraising expenditures, gifts to non-qualified donees, books and records, T3010]
• J.B Brass of Canada [2006 – scholarships, foreign activities, lending registration, disbursement quota, official donation receipts, books and records, T3010 inaccuracies, T3010 late]
• Evidence Ministries [2007-foreign activities and funding missionaries, books and records, T3010, T4s]
• Fondation québécoise Monde d’enfants  [2007]
• The Redemption Power International Ministry [2007 – books and records, foreign activities, official donation receipts, T4s]
• Peace Light Ministries [2006 – books and records, official donation receipts, foreign activities]
• Power of Prayer Ministry-Brampton  [2007 – foreign activities, official donation receipts, T4s]
• Friends of the Lord's Ranch [2007 – Control of Activities Outside Canada and Gifts to Non-Qualified Donees, Disbursement Quota,  T3010, Books and Records, Official Donation Receipts]
• Christ Salvation Church of God Ministries Canada Incorporated [2007 -Payments made to Nigeria totalling CDN$549,850; No agreements were in place to govern the use of the funds in Nigeria; Official Donation Receipts did not comply with the Income Tax Act, Payments were made to visiting pastors totalling $210,000 and no T4s or T4A's were issued for these payments, Books and records]
• Whit-Tee Youth Shelter Inc. [2007 – Books and Records, T3010, Official donation receipts]
• Africa Disaster Relief Initiative [2007 – donation receipts, keeping books and records in Canada, T3010]
• The National Action Committee on the Status of Women Charitable and Educational Trust [2007 – books and records and Disbursement quota]
• Canadian Friends of Collel Square [2006 – Funds sent overseas for scholarships, Official Donation Receipts]
• Pan African Canadian Multicultural Center [2007 – Books and Records, Official Donation Receipts, Objects, T3010, Remuneration & Benefit Reporting]
• Halacha L'Moshe Talmudic Institute [2006 – Activities outside of Canada, Agents, Books and Records, Scholarships, donation receipts, T3010]
• Christ Healing Prayer Centre Ministry [2007- Books and records, T3010, Official donation receipts, activities outside of Canada]
• Hope Economic Relief Organization [2007 – Books and Records, Donation Receipts and T3010]
• Canadian Single Adult Ministry Inc. [2007 – Tax Planning donation arrangement, Official Donation Receipts, Books and Records, Remuneration and Benefits, T3010]
• Human Life International in Canada Inc. [1994 – Political activities]
• La Societe Kalev d'Assistance benevole EnrKalev Free Loan & Aid Society [2006 -loans, foreign activities, books and records]
• Domaine Rosicrucien de Lachute [2000]
• Alliance for Life [1995 – political activities]
• The Press Foundation [2004 -activities outside Canada, scholarships, conduit, payment to specific student, lending registration, personal benefits, books and records, loans]
• Maison Jean-Fracois Dumais [2005]
• Canadian's Against Child Abuse Society [2005 – books and records, unreported income, personal benefits, fundraising costs, donation receipts, T3010, remuneration reporting]
• New Age International Foundation [1990 – Objects, Books and Record, Receipts, Benefit to members, Disbursement quota]
• Bayit Lepletot [2005 – Direction and Control, Documentation, Agency Agreement, T3010, Receipts]
• The Skies Above Canada Foundation [2005 -Gifts to non-qualified donees, disbursement quota, directed donations, lending registration, official donation receipts, lending registration, books and records]
• TLC Counselling Ministries Association [2006-personal benefits, large abnormal expenses, foreign activities, official donation receipts, books and records, T3010]
• La Societe litteraire de Tocqueville [2006 – books and records]
• Voice of Hope of Canada [2006 – books and records]
• The Wabuno Wildlife Trust [2006 – Books and records]
• African Foundation for Development Canada [2006 – books and records, official donation receipts]
• Pentecostal Church of the Redeemer (Toronto) [2006 – Books and record]

[Update – here are some more recent links:

https://www.canadiancharitylaw.ca/blog/revocation_letters_by_cra_for_charities_and_political_activities_over_the_l

https://www.canadiancharitylaw.ca/blog/some_historical_cra_letter_when_registered_charity_status_is_revoked_part_i  ]