Revocation letters

Over the last decade, we have provided to the public CRA letters relating to a number of Canadian registered charity revocations. These letters from CRA cover many different grounds for de-registration. Some relate to relatively minor matters, such as an organization being inactive for many years, to more serious matters, such as lacking appropriate direction and control, private benefits, and even terrorism.

These letters set out the CRA reasons for revocation of charitable status when CRA is alleging cause or that the revocation was as a result of an audit and non-compliance (as opposed to voluntary revocation or failure to file). You can request other documents directly from CRA using the CRA website.

CRA is only allowed to release very limited information on a deregistered charity, such as these letters, and only after deregistration. You can contact the former charities if you wish to obtain additional information. Because CRA alleges in a letter a particular set of facts does not make it necessarily correct. Many of these revocations have not been tested in court.

There have been many dozens of cases in the Federal Court of Appeal with charities challenging the CRA revocations (or refusal to register a charity). Although sometimes the court will disagree with some of the grounds, I am not aware of any cases in the last two decades of the Federal Court of Appeal overturning the charity revocations of CRA.

Why should people care about the revocations of charities? The ability of CRA to revoke the registration of a registered charity can have a 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 the 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. Unfortunately, CRA does not give detailed guidance on certain topics, and these letters are also helpful in understanding certain topics not covered by the guidance.