Often the Charities Directorate of CRA updates its guidance and it does not alert the public to the change. So, I was pleased that the Charities Directorate recently released a press release that they had updated their guidance CG-029 Relief of poverty and charitable registration. They have also put in a version history at the bottom of the document reproduced below.
9. Version history
Version number Revision Reason for revision Issued 2.0
- Added information on how to determine whether a person or a household is eligible for affordable housing in a particular community or area. Highlights the possible use of provincial or municipal criteria that are consistent with Government of Canada funded affordable housing programs across Canada.
- Added information on the new granting regime in the Income Tax Act.
- Made plain language edits, updated terminology, and reorganized content.
- Added more examples.
- Periodic review
- Highlights the possible provincial or municipal criteria that are consistent with Government of Canada funded affordable housing programs across Canada to determine eligibility for affordable housing.
- Introduction of the new granting regime in the Income Tax Act.
Revised October 23, 2024 1.0
- First version of the guidance product
- New
November 27, 2020
While this version history is helpful, I have suggested that the Charities Directorate have a single page that lists all changes (minus just typos) so that everyone is easily able to see what pages have been added or changed, but that suggestion has never been accepted. Unfortunately, unless people regularly check each guide to see if there has been a change (or a version history), you may not be aware of the changes.
Probably the number 1 thing that charities do is relief of poverty; therefore, this guidance is important and should be reviewed by many charities.
The three main updates to the guidance on poverty are:
- Inclusion of provincial and municipal criteria for affordable housing eligibility programs across Canada;
- Expansion on charitable benefits that relieve poverty provided in certain circumstances to non-charitable beneficiaries; and
- Discussion of the new grant to grantee regime, in addition to direction and control.
Here are some of the major changes:
Eligibility of Affordable Housing Programs
22. To determine whether person or household is eligible for affordable housing in a particular community or area, a charity can use provincial, or municipal criteria that are consistent with Government of Canada funded affordable housing programs across Canada, such as:
- Quebec — core need income threshold
- British Columbia — housing income limits
- Alberta — income thresholds
- Toronto — rent-geared-to-income-housing
Examples of criteria that are consistent with Government of Canada funded affordable housing programs across Canada
For a household requiring three-bedroom accommodation, the following are consistent with Government of Canada funded affordable housing programs across Canada:
There is also a short note about when non-charitable beneficiaries could benefit from a relief of poverty program
7. Charitable benefits that relieve poverty provided to non-charitable beneficiaries
25. There are instances where providing a charitable benefit that relieves poverty to a non-charitable beneficiary is an incidental private benefit.
26. Providing charitable benefits that relieve poverty to non charitable beneficiaries must be shown to support, facilitate, or contribute to a charity’s ability to further a purpose to relieve poverty. In addition, providing the charitable benefit should be necessary, reasonable, and proportionate to the public benefit that results from furthering the purpose.
Example where providing charitable benefits that relieve poverty to non charitable beneficiaries is incidental private benefit
The following is as example where providing charitable benefits that relieve poverty to non charitable beneficiaries is incidental private benefit:
- providing school breakfast or lunch program
Including all students in the program, regardless of whether or not they are experiencing poverty, can avoid stigmatization, and foster an inclusive environment.
Providing charitable benefits to non-eligible beneficiaries is necessary, reasonable, and proportionate to the public benefit that results from furthering the purpose.
Another change is incorporating the new grant to grantee rules in this guidance, in addition to the direction and control rules.
8. Other considerations
8.1 Operating in collaboration with a non-qualified donee (grantee or intermediary)
27. A charity that furthers its charitable purpose or conducts activities in collaboration with a non‑qualified donee (grantee or intermediary) should be aware of the following:
Grantee
- accountability requirements set out in Guidance CG-032, Registered charities making grants to non-qualified donees
Intermediary
- direction and control requirements set out in guidances:
Here is the recent CRA press release on the change to the relief of poverty guidance:
The guidance on the relief of poverty as a charitable purpose has been updated!
The Canada Revenue Agency (CRA) has revised its guidance CG-029 Relief of poverty and charitable registration to reflect recent changes to the Income Tax Act.
In this revised version, you will find more details and examples on how your charity can provide affordable housing. It also contains updated terminology, and information on the new rules for making grants to non-qualified donees.
Determine who is eligible for affordable housing
In Canada, a charitable purpose to relieve poverty can include providing affordable housing as a basic necessity of life and simple amenity. People experiencing poverty are those who lack these kinds of basic necessities of life or simple amenities available to the general population.
To help you better determine if a person or a household is eligible for affordable housing in a particular community or area, your charity can use provincial or municipal criteria that are consistent with Government of Canada funded affordable housing programs across Canada, such as:
- Quebec — core need income threshold (French only)
- British Columbia — housing income limits
- Alberta — income thresholds
- Toronto — rent geared to income subsidy
For more information on relief of poverty, please visit our pages Relief of poverty and Housing and charitable registration.
We’re here to help
For questions concerning the relief of poverty, please call our Charities Directorate client service team at 1-800-267-2384. Our representatives are available to help you Monday through Friday, from 8 am to 5 pm, Eastern time.