The Year in Review: 2004 Canadian Charity and Not-for-profit Law
Developments Related to Planned Giving.

 By Terrance S. Carter, B.A., LL.B and Theresa L. Man, Carter & Associates

 

A.  Introduction

Planned giving professionals should be aware of numerous legislative, regulatory and common law developments in 2004 that will significantly impact how charities operate in Canada and abroad. The following brief summary outlines the more important developments in this regard, including the new definition of gift for tax purposes, the new definition of charitable organization and public foundation, and the new regulatory regime under the Income Tax Act (the “ITA”). 

 

B.  TAX ISSUES
 

1.      February 27, 2004 Income Tax Amendments

Draft amendments to the ITA, released on February 27, 2004, constitute a consolidation of, and further amendment to, previously proposed amendments introduced on December 20, 2002 and December 5, 2003 (collectively referred to as the “February 2004 Amendments”),[1] and has not been passed by Parliament as of March 1, 2005.

a)            New Definitions

At common law, a “gift” must be transferred voluntarily, without any contractual obligation or advantage of a material nature returned to the donor.  A new concept of “gift” will be introduced to provide a tax benefit, where the value of the gifted property made after December 20, 2002 exceeds the advantage received.    

 

The current “contribution” test requiring that a charitable organization or public foundation receive not more than 50% of the capital contributed from one donor, will be replaced with a new “control” test, retroactive to January 1, 2000.  This will permit a charity to receive contributions of more than 50% of its capital from a person or a group of persons, provided that the donor(s) does not control the charity or represent more than 50% of the directors and trustees of the charity,.

 

b)            New Donation Deeming Provision

Changes to shut down “buy-low, donate-high” donation schemes providing donors with elevated tax benefits will be introduced as a result of concerns raised by the public and Canada Revenue Agency (“CRA”).  The ITA will be amended to provide that if a taxpayer acquires property through a “gifting arrangement” as defined in the ITA, then the fair market value (“FMV”) of the property donated, regardless of when the property was acquired, shall be “deemed” to be the lesser of (i) the FMV of the property and (ii) the cost of the property to the taxpayer immediately before the gift is made (the “Deeming Provision”), and will apply to gifts made on or after 6 p.m., December 5, 2003.  The Deeming Provision will not apply to inventory, real property situated in Canada, certified cultural property, publicly traded shares or ecological gifts. 

 

The Deeming Provision will also apply (1) if a donor acquires property and donates the property within three years of the date of acquisition, and (2) if it is “reasonable to conclude” that the donor intended to make a gift when the property was acquired, regardless of when the donor acquired the property, but will not apply to situations where a gift is made as a consequence of the donor’s death.  The burden of proof is on the donor to show that there was no intention to make a gift when the property was acquired. These amendments apply to gifts made on or after 6 p.m. on December 5, 2003, and will have serious practical implications on how charities accept gifts and issue donation receipts, including possibly requiring donors to provide written confirmation of when donated property was acquired.

 

c)          Restricting the Use of Limited Recourse Debt

Provisions will be introduced to curtail gifting arrangements involving limited-recourse debts incurred by donors by reducing the amount of the gift by the amount of the loan if the indebtedness is of limited recourse to the lender or if there is a guarantee, security or similar indemnity or covenant with respect to that debt or any other debts. These amendments will apply to donations made after February 18, 2003. 

 

d)            Substantive Gift

A new subsection will be included that applies to gifts of capital property and eligible capital property (“substantive gifts”) made on or after February 27, 2004, to prevent donors from avoiding application of the Deeming Provision by disposing of property to a qualified donee and then donating the proceeds of disposition to either that qualified donee or to another qualified donee who does not deal at arm’s length with the qualified donee that purchased the property, rather than donating the property directly to the qualified donee.  Under these situations, the FMV of the substantive gift or the proceeds of sale would be “deemed” to be the lesser of the FMV of the property sold and the cost of the property to the taxpayer immediately before the sale of the property.

 

e)           New qualified donee

The list of “qualified donees” will be expanded to include municipal or public bodies performing a function of government in Canada. 

2.            December 6, 2004 Income Tax Amendments[2]

 

Draft income tax amendments implementing the 2004 Federal Budget were released on September 16, 2004, and further amended and consolidated by a Notice of Ways and Means Motion tabled on December 6, 2004 (the “December 2004 Amendments”).  The resulting Bill C-33 was passed by Parliament on February 25, 2005.  These amendments, summarized below, generally apply to taxation years beginning after March 22, 2004, with some exceptions being in effect 30 days after Bill C-33 receives Royal Assent, and do not affect the changes embodied in the February 2004 Amendments.

 

a)            New intermediate sanctions

Intermediate sanctions will be introduced to provide an alternative to revocation of charitable status for minor or unintended infractions, including taxation of gross revenue derived from business activities, suspension of tax-receipting privileges, monetary penalties, and taxation of gifts and transfers to other registered charities. Some sanctions are progressive, increasing in severity for repeat infractions within a 5 year-period. 

 

b)            Annulment and revocation

The Minister will now have explicit authority to annul an organization’s registration if it was registered in error or if it has ceased to be a charity “solely as a result of a change in law.”  Annulled organizations will be deemed not to have been registered at all and the Part V revocation tax will not apply, but official receipts issued prior to annulment will be accepted as valid.  The Minister also retains the right to revoke the registration of a charity in the event of severe breaches of the ITA.  These amendments also require the assets of a charity whose registration has been revoked to be transferred to an “eligible donee,” rather than a qualified donee. 

 

c)            Appeals

The appeal process will be more accessible and affordable for registered charities and unsuccessful applicants for charitable status. CRA’s internal review process will be extended to notices of a decision by the Minister regarding the revocation or annulment of a charity’s registration, designation of a charity as a private or public foundation or charitable organization, denial of applications for charitable status, and imposition of taxes or penalties against a registered charity.  Appeals of decisions concerning refusals to grant registered charitable status and revocation of registered charitable status will continue to be made to the Federal Court of Appeal, while taxes and penalties will be appealed to the Tax Court of Canada. 

 

d)           Transparency and accessibility of information

The Minister will have the authority to release additional information to the public, including grounds for revocation or annulment; financial statements; decisions of CRA regarding notices of objection; identification of registered charities subject to sanctions, the type of sanction imposed, and grounds for the sanction; information to support an application by a registered charity for special status or an exemption under the ITA; and reasons for denying the registration of organizations.  Further, official donation receipts issued after 2004 will be required to include the current internet address of CRA. 

 

e)            New disbursement quota rules

The 4.5% disbursement quota will be reduced to a more manageable rate of 3.5% for taxation years beginning after March 22, 2004.  The 3.5% disbursement quota, previously only applicable to public and private foundations, will also apply to charitable organizations, if the value of their investment assets exceeds $25,000.   

In addition, a new concept of “enduring property” was introduced, which includes gifts received by way of a bequest or inheritance (including gifts of life insurance proceeds, RRIFs and RRSPs as a result of direct beneficiary designation), ten-year gifts, and gifts received by a charity as the transferee of an enduring property. In general, a charity will be permitted to encroach on the capital gains of enduring property up to a maximum of the lesser of 3.5% of the charity’s investment assets and its “capital gains pool,” which is the realized capital gain from the disposition of enduring property declared by the charity on its T3010 Information Return.

 

Finally, transfers from registered charities to charitable organizations, previously exempt from the 80% disbursement quota, will be subject to the 80% disbursement requirement, except those involving specified gifts and enduring property. 

 

While many aspects of the proposed new disbursement quota rules reflect an attempt by the Department of Finance to address a number of difficulties facing charities, the complexities introduced are such as to make them more difficult, if not impossible, for the average charity to understand, let alone comply with. In addition, there are concerns that the proposed amendments represent a major change in tax policy that will blur the line between public foundations and charitable organizations.

 

C.  OTHER INITIATIVES AFFECTING CHARITIES[3]
 

The decision in Brantford General Hospital Foundation v. Marquis Estate[4] reinforced the long standing common law principle that a pledge is unenforceable for lack of consideration.[5] The conclusions that can be drawn from this decision are, (1) when drafting a will, it is important to ensure that the testamentary gift will continue to honour the inter vivos gift and allow for the testator’s wishes to be fulfilled, (2) a pledge is not a binding contract, as a pledge must be accompanied by consideration to be enforceable, and (3) the doctrines of part performance and estoppel only allow enforcement of a pledge in cases where there is a pre-existing legal or contractual relationship between the parties.

 

In September 2004, the CRA released “Charities in the International Context,” which provides operational guidance to Canadian charities operating abroad, with the stated rationale, in part, of ensuring that the tax benefits reserved for Canadian charities are not used to provide support to terrorism in the guise of charity. It affirms that charities continue to fall under the jurisdiction of Canadian statutory and regulatory authorities and identifies resources that address the boundaries within which charitable activities must be carried out.[6]

 

British Columbia introduced the Charitable Purposes Preservation Act in response to the decisions in the Christian Brothers of Ireland in Canada cases,[7] in which the courts found that property held in special purpose charitable trusts can be seized by a creditor to satisfy debts owed to tort claimants, even if those claims arise from circumstances unrelated to the trust in question. This Act addressed this concern by supplementing the law of trusts, as it relates to charitable giving, by expressly recognizing and protecting discrete purpose gifts and setting out the obligations such gifts impose on recipient charities and the courts.

 

In April 2004, the Uniform Law Conference of Canada, Civil Law Section, (ULCC) released a position paper on “Charitable Fundraising.” The resulting draft Uniform Charitable Fundraising Act, expected by August 2005, is anticipated to affect charities across Canada by addressing instances of fraudulent, inept and unethical fundraising practices by charities and fundraising businesses, which undermine the integrity of the sector.

 

About Terrance S. Carter, B.A., LL.B.

Terrance Carter practices primarily in the area of charity and not-for-profit law, with an emphasis on fund raising, gift planning, religious organizations and international strategic planning. Mr. Carter is a member of Canada Revenue Agency's (CRA) Charity Advisory Committee, and is recognized as one of the leading experts in the area of charity and not-for-profit law in Canada by Lexpert.

 

Mr. Carter is a member of the Technical Issues Committee of CRA's Charities Directorate representing the CBA, is Past Chair of the Charity and Not for Profit Law Sections of both the Canadian Bar Association (CBA) and Ontario Bar Association (OBA), and a member of the Government Relations Committee of the Canadian Association of Gift Planners (CAGP). He is also a member of the Association of Fundraising Professionals, the International Center for Not-for-Profit Law in Washington, D.C., and the American Bar Association Tax Exempt Section, has participated in consultations with the Public Guardian and Trustee of Ontario and the Charities Directorate of CRA, and was a member of the Bill C-36 Anti-terrorism Committee of the CBA in its submission to Parliament.

 

Mr. Carter has written numerous articles and has been a frequent speaker on legal issues involving charities and not-for-profit organizations for numerous groups across Canada, as well as internationally, including the Law Society of Upper Canada, the CBA, the OBA, the Association of Fund Raising Professionals, the American Bar Association, the CAGP, the Canadian Tax Foundation and The Institute of Chartered Accountants.

 

 

About Theresa L. M. Man, B.Sc., M.Mus., LL.B.

Theresa L.M. Man joined Carter & Associates in 2001 to practice in the areas of charity and not-for-profit law, corporate and commercial law and real estate, after having practiced at a law firm in Toronto and having been a sole practitioner in Markham for four years. Ms. Man has been actively involved with numerous charities, either as a legal advisor or as a member of the Board of Directors. She has been involved in various seminars and is an invited speaker at a seminar regarding not-for-profit organizations hosted by the Canadian Bar Association. Ms. Man has also written on a number of legal topics for www.charitylaw.ca, including the 2004 Federal Budget and amendments to the Income Tax Act

 


[1] For more information, see Terrance S. Carter and Theresa L.M. Man. “February 27, 2004, Revised Draft Amendments to the Income Tax Act Affecting Charities.” Charity Law Bulletin No. 40 (March 29, 2004). www.carters.ca.

[2] For more information, see Terrance S. Carter and Theresa L.M. Man. “December 2004 Amendments to the Income Tax Act Affecting Charities.” Charity Law Bulletin No. 61 (January 12, 2005). www.carters.ca.

[3] CRA policy statements and publications are available at http://www.cra-arc.gc.ca/menu-e.html.

[4] (2003), 67 O.R. (3d) 432 (Sup. C.J.)

[5] For more information, see Terrance S. Carter. “Ontario Superior Court of Justice Reaffirms Unenforceability of Pledges.” Charity Law Bulletin No. 49 (July 30, 2004). www.carters.ca.

[6] For more information, see Terrance S. Carter and Sean S. Carter. “Worldwide Implications of America’s Emerging Policies Concerning NGOs, Non-Profits and Charities.” Anti-Terrorism and Charity Law Alert No.5 (2004). www.antiterrorismlaw.ca.

[7] For more information, see Terrance S. Carter. “Donor-Restricted Charitable Gifts: A Practical Overview Revisited II, Parts I and II.” The Philanthropist Vol. 18, No. 1 & 2. (2003). http://www.charitylaw.ca/articles.html

 

 
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