Readout: Advisory Committee on the Charitable Sector – October 12 and 13, 2023

The Advisory Committee on the Charitable Sector (ACCS) met in Ottawa in person for a two day meeting, held on October 12 and 13, 2023.

October 12, 2023

Soren Halverson, Assistant Commissioner of the Legislative Policy and Regulatory Affairs Branch of the Canada Revenue Agency (CRA), opened the meeting by taking a moment to acknowledge the traditional land and unceded territory of the Algonquin Anishinaabeg People. He also introduced Kevin McCort as the new sector co-chair of the ACCS.

The sector co-chairs, Sheherazade Hirji and Kevin McCort, noted that the purpose of the meeting was to review the recommendations or positions of the four ACCS working groups with the objective of providing written recommendations or advice to the Minister of National Revenue before April 30, 2024.

Robert Delaney, Director, Charities Directorate, delivered a presentation on the Charities Directorate’s Technical Issues Working Group (TIWG). The purpose of this presentation was to provide ACCS members with an overview of the working group, and how the TIWG differs from ACCS when considering their respective mandates. He noted that the ACCS is a consultative forum to discuss broader policy, legislative, and administrative issues impacting the charitable sector, whereas the TIWG identifies issues and explores workable solutions to technical issues related to the application of the Income Tax Act and common law.

Next, there was a roundtable discussion for members to raise any current or emerging issues and four items were identified:

• Reporting administrative burden caused by the new reporting rules for Trusts (T3)
• Legislative changes impacting the Alternative Minimum Tax and the impact it may have on charitable giving
• Various human resource issues facing the sector – staffing issues, employment shortages, and a decrease in volunteerism
• Proposal from the Accounting Standards Board to change the current accounting standards which, if implemented, would make it difficult to reconcile financial statements with the T3010, Registered Charity Information Return

Each of the four ACCS working groups had an opportunity to present their positions or recommendations to the committee. The working groups are:

• Definition of charity and charitable purpose working group (DCCPWG)
• Transparency and data related to other qualified donees and non-profit organizations working group (TDWG)
• Relationship between the CRA and the charitable sector working group (CRACSWG)
• National inherent risk assessment working group (NIRAWG)

The purpose of this discussion was to ensure all ACCS members had a good understanding of the recommendations being put forward by each working group. Members used this opportunity to discuss the recommendations in plenary, seek clarification when needed, and challenge ideas by offering different perspectives. Using this advice, guidance and feedback, each working group is refining and finalizing its recommendations. The ACCS plans to present their final recommendations or positions to the Minister of National Revenue by April 2024.

October 13, 2023

On October 13, the Minister of National Revenue, Marie-Claude Bibeau, attended the meeting virtually and provided the opening remarks. The Minister recognized the work accomplished to date, thanked members for their time and commitment to the ACCS, and outlined her priorities as Minister of National Revenue, which are:

• Canada's tax system is fair and equitable for all
• Canada Revenue Agency is recognized for its concrete and effective contribution to the redistribution of wealth
• Canadians receive the credits and benefits that are due to them

The Minister conducted a roundtable where she asked each member to introduce themself and identify any challenges or issues impacting the sector. In closing, the Minister acknowledged the ACCS is representing a diverse population which can be challenging; however, she noted that the ACCS and the charitable sector have an important role to support Canadians that need it most.

Home in Government

Kevin McCort led a discussion on a “home in government” for the charitable sector. He noted that this was a recommendation made by the previous iteration of the committee in Report #1 and felt it may be helpful to determine where it currently stands. After providing an overview and update, Kevin opened the floor for discussion. The ACCS did not have consensus on whether they should pursue this item further. It was agreed that there are too many unknowns to determine if a ”home in government” would be advantageous to the sector.

Social Innovation Advisory Council

Michael Toye, Chair of the Employment and Social Development Canada, Social Innovation Advisory Council (SIAC), provided an overview of the Council and information about the Social Innovation and Social Finance Strategy. He also shared his perspective on the work of the SIAC and its impact on non-profit organizations, given the intersectional agenda between the CRA and Employment and Social Development Canada as a result of the social enterprise agenda.

Update for the charitable sector on the work of the ACCS

Members discussed providing an update for the sector on the work of the ACCS. They agreed they should offer a session in French and English and noted this would be a good opportunity to introduce Kevin McCort as the new sector co-chair, provide an update on their work, and engage with the sector.

The sector co-chairs concluded the meeting with a final roundtable and asked members their initial thoughts on whether the meeting accomplished its objective. All members noted the meeting was productive and they are looking forward to finalizing their working group recommendations. The Sector co-chairs closed the meeting.