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…