The audit concerned the organization's activities in the period from 1 January 2011 to 31 December 2012. 34; According to subsection 149.1(1) of [the Income Tax Act J, a charitable organization must devote all its resources to charitable activities carried out by the organization itself. Checking and maintaining the organization's other records, such as meeting minutes and incorporating documentation.
Therefore, it is our view that the organization has failed to establish compliance with the requirement that it maintain direction and control over its resources. As a result, it is our opinion - that the organization is awarding non-qualified donees in violation of the law (more details on funding to non-qualified donees are discussed below), .. b) Funding of non-q1, Jaalified donees. During our audit, we conducted a review of the resources the organization spent on political activities.
As mentioned above, it is our opinion that the Organization does not retain direction and control over the maintenance of this website. It is our opinion that the political activities on the website are funded by the Organization. It is therefore our view that the Organization has not complied with the requirements of subsections 149.1 (1) and the Act to which it relates.
The organization did not keep its own books and records (such as donation receipts, government documents, notes of joint meetings, legal expenses invoices and full details of bank transfers).
Failure to maintain proper donation receipts_
For this reason, it appears that there may be grounds for revoking the Organization's charitable status under paragraph 168(1)(d) of the Act. It appears that the Organization was claiming amortizations related to or paid on behalf of-. However, we were unable to .. determine the exact amount of Organizational resources that were used to engage.
The organization's statement of operations is our opinion that the Organization is not in compliance with s. Brai1ov ceased to be a director of the Organization prior to the time of your audit. You also comment about the control and direction of the Organization in the context of the Organization's_n:wrds.
We have explained::d aboYe that the publication of Ul\!D Voice is a business connected with the operations of the Organization. United Macedonian Diaspora (Canada) I Diaspora macedoniens (Canada) COMMENT ON REPRESENTATIONS OF SEPTEMBER 23, 2014 The audit carried out by the Canada Revenue Agency (CRA) identified that the United Macedonian Diaspora (Canada) I Diaspora macedoniens unis (Canada) . the Organization) does not devote its resources to charitable activities carried out by the Organization itself. Control and maintenance of other records of the Organization such as minutes of meetings and incorporation of documentation.
Branov ceased to be the director of the organization before the time of the [CRA] audit. Jim Daikos, director, told us that the directors have not changed since the organization's T3010 annual return was filed for 2010 and that Mr. The submissions stated that the CRA had not provided any evidence to suggest that the website was actually the organisation's website.
However, the existence of an undisclosed official does not alleviate our concerns about the direction and control of the Organization's resources. The organization's submissions claimed that it "see[s] no relevance between the comments of a third party making statements to its audience for its own purposes and the truth necessary to justify [CRA's] audit position". He also - controlled other records of the organization such as minutes of meetings and incorporation documents.
The Organization's representative offices did not provide information that would challenge our position that - controls the Organization's records.
The organization's statements dated September 23, 2014 agreed with our position that publication of the magazine is not a charitable activity. As we agree with the Organization's assertions that the magazine is a non-charitable activity, reclassifying the issues does not change the agreed position that this is a non-charitable activity. During the audit, we asked the organization for more detailed information about both fundraising events.
Furthermore, since the majority of the organization's fundraising income is for the benefit of non-qualified donors, our position remains that this activity. 34;[l]it is our opinion that the Organization does not manage or control the hosting of this website. It is our opinion that the political activities on the website are funded by the Organization."
The Organization's representations on September 23, 2014 agreed that the Organization does not maintain direction and control over the hosting of the Website. As stated above, it remains our view that the Organization helps fund the website, which includes the website's political activities. It was our view that the organization had not clearly demonstrated how these meetings and publication of text furthered its charitable purpose.
The organisation's representations of 23 September 2014 did not address how these meetings and publication of text further the organisation's charitable purposes. Since the organization's representations did not provide additional information and supporting material to show how these activities are connected to a charitable purpose. The organization's representations of 23 September 2014 did not support all of its expenses and could not account for all of the resources it provided to · or.
Therefore, we are still unable to determine the amount of the Organization's resources that are used to carry out political activities. Regardless, our position remains that the Organization has not met the requirements of subsections 149.1 (1) of the Act that it devotes substantially all of its resources to charitable activities supported by the. For this reason there are grounds for revoking the charitable status of the Organization under paragraph 168(1)(b) of the Act.
Instead, the representations pointed out that it is only a question of the resources dedicated to the activity of meeting with political leaders that needs to be addressed. 149.1, subsection 1 and in the Act, namely that it devotes substantially all of its resources to charitable activities carried out by the organization itself and that it does not engage in partisan political activities. For these reasons, there is reason to revoke the organisation's charitable status under section 168(1)(b) of the Act.
These were maintained by - at an address other than an address in Canada as registered by the Minister, in direct contravention of subsection 230(2) of the Act. As a result, our position remains that the organization has failed to keep adequate books and accounts under subsection 230(2) of the Act. Therefore, there are grounds for revoking the organisation's charitable status under section 168(1)(e) of the Act.
Consequently, it remains the CRA's view that the Organization has failed to keep proper donation receipts and that there are grounds for revoking the Organization's charitable status under paragraph 168(1)(d) of the Act. Therefore, it is our view that the Organization does not comply with the subsection of the Act and therefore and that there are grounds for revoking the Organization under paragraph 168(1)(c). The Minister may, by registered post, give notice to a person described in any of paragraphs (a) to (c) of the definition “made eligible” in subsection 149.1(1) that the Minister proposes to revoke his registration if the person. a) apply to the minister in writing for revoking the registration;
{c) the income of the charity for the period of liquidation, including gifts received by the charity during that period from whatever source and any income that would be calculated under section 3 as if that period were a tax year; And. {c) an amount in respect of any property transferred by the charity during the liquidation period and not later than the later of one year from the end of the tax year and any day referred to in paragraph {1.2) {c), to a person who at the time of the transfer was an eligible donee with respect to the charity, equal to the amount, if any, by which the fair market value of the property, upon transfer, exceeds the consideration paid by the person for. A person who, after the time 120 days before the end of the taxable year of a charity deemed to have ceased under paragraph (1), receives property from the charity shall be jointly or severally liable with the charity for the purposes thereof subsection (1.1) tax payable by the charity for such taxable year in an amount not to exceed the aggregate of all credits, each of which is the amount by which the fair market value of such property at the time it was so assessed by the charity person receives exceeds the consideration given by the person for the property.
If assets have been transferred to a charitable organization under circumstances described in subsection 34;net value" of property owned by a charitable foundation on the day of its transfer means the amount determined by the formula. If the Minister has assessed a particular person with respect to that person's criminal liability under section 188.1 for a tax year , and that the liability exceeds DKK 1,000, that.
