CRA, Religion and Politics
February 24, 2010
Blogs, websites and the traditional media reported recently that King’s Glory Fellowship Association in Calgary had its charitable status revoked for too much commentary on issues such as abortion, divorce, and homosexuality. These reports have caused a great deal of concern at CCCC and other Christian ministries. CCCC has looked into this case and has the following comments.
CRA’s website reveals that the revocation occurred more than a year ago on January 10, 2009 for failure to file their T3010 annual return. CRA confirmed to CCCC that the last T3010 on file is for 2006.
King’s Glory has applied to regain registered charity status, and like all charities that have their status revoked, they must go through the entire application process as if they had never been registered. There is no ‘reinstatement’ of charitable status. Their application resulted in a letter dated October 29, 2009 from CRA (which the church authorized CCCC to see) saying that it is not likely, without further information being provided, that they can be registered. There are five issues that need to be addressed by King’s Glory, and they were given 60 days to provide additional information if they wished to proceed with the application. This is standard CRA procedure.
One of the issues raised by CRA, and the one that is of grave concern to CCCC and our members, is CRA’s statement that “members of the Board of Directors [of King’s Glory] espouse strong negative views about sensitive and controversial issues, which may also be viewed as political, such as abortion, homosexuality, divorce, etc.”
The issue is whether expressing views on issues such as the sanctity of life, sexuality and social structures is a charitable activity or a permitted political activity. The CRA Charities Officer, in this letter, has interpreted such views as permissible political activity, and then ruled that King’s Glory has exceeded the maximum amount of political activity that a registered charity may conduct.
CCCC takes the view that, for a Christian ministry, speaking out on these issues is not a permissible political activity but a charitable activity, because it is directly related to the advancement of the charity’s understanding of the Christian faith. We believe this position is supported by CRA’s own policy statement on political activity (CPS-022).
The line between what is charitable activity and what is political activity must be determined by identifying the purpose of the activity and comparing that to the charity’s charitable purpose. For example, sermons and study programs offered by a church to promote an understanding of the moral issue is clearly an activity in pursuit of the church’s primary charitable purpose. A call to change or retain a law is not charitable activity for the church, but it is a permissible political activity. And the line between permissible and prohibited political activity would be crossed if the church told people which candidate or party to support.
CCCC raised the King’s Glory case in a recent meeting with the Charities Directorate and received confirmation that CRA’s position on what constitutes political activity has not changed. It was affirmed that speaking to these issues is not, on its own, political activity. This particular case has a number of complicating factors, but the church should be able to address them. (CRA does offer some leniency regarding the sixty day reply period.)
On the broader issue of being able to speak out on issues related to the practice of our faith, should CRA attempt to redefine what is now charitable activity as political activity, CCCC will act to protect the right of Christian ministries to engage in charitable activities.
Our advice to members is:
- Ensure the T3010 is filed annually and reaches CRA by the six month deadline.
- Read the article “Defining the Line” from the Bulletin Issue 5, 2003 which reviews the distinctions between charitable activities, permissible political activities and prohibited political activities. The article is available electronically in the Members section of our website under “Political Activities”.
