Representations to government as a charitable activity

Criteria for representations to be considered charitable

  • Given their unique perspectives and expertise, it is recognized that charities make a valuable contribution to the development of public policy in Canada.

  • The provisions of the Income Tax Act related to political activities are not meant to restrict the contribution of charities to public policy. Therefore, if a charity makes a representation to an elected representative or public official, with or without an invitation, this will generally be considered as a charitable activity. For more information, see section 7.3 of Policy statement CPS-022, Political activities.

  • Representations to elected representatives or public officials must:

    • only be undertaken as an activity that is subordinate to a charity’s charitable purposes

    • relate to an issue that is connected to the charity's purposes

    • be well-reasoned

    • not contain information that the charity knows or ought to know is false, inaccurate, or misleading

  • If making representations becomes a charity’s sole or primary activity, the Canada Revenue Agency (CRA) would likely conclude that the charity had adopted either a collateral, non-charitable purpose or a political purpose. The charity could then be subject to compliance measures, including suspension of its tax-receipting privileges, or revocation of its charitable status.

  • If a charity made a representation that was not connected to its charitable purposes, the CRA would also likely conclude that this was not an acceptable use of resources. For example, if a charity were registered with the sole charitable purpose of advancing education by providing scholarships, yet made representation to a government calling for a reduction in general sales taxes, the CRA would not consider this representation to be connected to its charitable purposes.

  • Finally, a representation must always be non-partisan. It must never include any direct or indirect support or opposition to a candidate or political party.

What kinds of representations might be considered charitable?

  • Whether a representation meets all the criteria described in section 7.3 of Policy statement CPS-022, Political activities, will always depend on the specific facts of the individual case. Examples of representations that, depending on the circumstances, might meet all the criteria include:

    • a meeting at a member of Parliament’s office where a charity delivers an oral argument urging the member to support legislation that is related to the charity’s charitable purpose

    • a presentation delivered to a public official at a charity’s headquarters to explain the charity’s findings on a public policy issue that relates to the charity’s purposes and call for a government policy to be changed

    • an appearance before a parliamentary committee to speak about a charity’s experiences in its field of operations and to urge the committee to support/amend proposed legislation

    • a presentation at a municipal government town hall meeting to provide a charity’s views on the benefits to its programs of proposed changes to a municipal bylaw and call for the changes to be implemented

Releasing the text of a representation

  • Releasing the text of a representation before or after delivering it to the elected representative or public official will be considered a charitable activity provided that the entire text is released and there is no explicit call to political action either in the text or in any reference to the text.

  • The charity may issue the entire representation to the public by press release; its website; or explaining in a newsletter that it intends to make, or has made, the representation and is willing to distribute the information to anyone who wants a copy.

  • In all cases, the entire representation should be made available.

  • Should a charity make an explicit call to political action in any part of this representation or in reference to it, the activities could be regarded as political activities and, as a result, all resources and expenditures associated with these activities could be considered to have been devoted to a political activity.

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