Current Developments In The Application Of Paragraph 149(1)(1) Of The Income Tax Act

I. INTRODUCTION Organizations that meet the requirements of paragraph 149(1)(1) are often referred to as “non-profit organizations” (“NPOs”). This article provides an overview of the law and Canada Revenue Agency’s (“CRA”) positions on the requirements of paragraph 149(1)(1), with an emphasis on several recent technical interpretations that appear to narrow the circumstances in which CRA…

Letter From The Editor

The comprehensive article featured in this issue of The Philanthropist discusses the availability of tax-exempt status for organizations that are not registered charities but, rather, are nonprofits established for social welfare, civic improvement, pleasure or recreation, or for any other purpose except profit. This topic has become increasingly relevant in the last few years because…

Recent Tax Developments

The Tax Editors are indebted to Holly MacLachlan-Toonders of Peat Marwick Thorne for this explanation of complex but crucial problems affecting many charitable organizations. Fund-Raising Events and the GST Because of the importance of fund raising to charitable organizations, this column is devoted entirely to the goods and services tax implications arising from fund-raising events….

Counterpoint

A Response to “Commercial Nonprofit Enterprises in the United States: The Phenomenon of Unfair Competition”1 and Unfair Competition: The Profits of Nonprofits For nearly a decade, a vocal segment of America’s small business community, with government support through the Small Business Administration, has accused commercially active nonprofit organizations of having an unfair competitive advantage. Two…

Bookshelf

The Economics of Non-Profit Institutions: Studies in Structure and Policy Edited by Susan Rose-Ackerman Published by Oxford University Press, New York, 1986 ($59.95) REVIEWED BY MICHAEL J. TREBILCOCK Faculty of Law, University of Toronto This book of essays is one of a series of research publications which have emerged from Yale University’s Program on Non-profit…

Recent Tax Developments

The Goods and Services Tax: An Update for Charities and NonProfit Organizations [For several years the federal government has been preparing the Cana­dian public for the introduction of a new federal sales tax, now known as the Goods and Services Tax. This article was developed from an article in Network, the newsletter of The Canadian…