Mandate letters issued by the Prime Minister again raise concerns about charitable status.

On December 16, 2021 the Prime Minister issued mandate letters to all cabinet ministers. These are intended to set out the objectives for each minister. Two letters are concerning because they instruct Ministers to introduce or support the introduction of:

“… amendments to the Income Tax Act to make anti-abortion organizations that provide dishonest counselling to pregnant women about their rights and options ineligible for charitable status…”

You can find the directives in these letters:

On November 24, 2021, CCCC wrote to the federal government about similar statements that had been made prior to the Parliamentary Session. The government had pledged to remove charitable status for “anti-abortion organizations (for example, Crisis Pregnancy Centres) that provide dishonest counselling to women about their rights and about the options available to them at all stages of pregnancy.”

With the mandate letters, CCCC continues to express deep concern over the proposed amendments. No charity should be de-registered solely on the basis of a pro-life belief or conscience. At risk of stating the obvious, this belief is quite legal to hold. To de-register a charity on the basis of such beliefs therefore raises immediate and significant Charter and procedural fairness concerns. Likewise, no type of charity should have its work mischaracterized, or be labelled with an undefined allegation of dishonesty.

But as a Christian organization, we also do not stand for dishonest conduct. Thankfully, existing parts of the Income Tax Act already address concerns about dishonesty in the charitable sector.

As we explained in our November 29 blog post, CCCC Asks for Clarity on Charitable Status, our letter asked the government for clarity about its intention and addressed any future process.  We will continue to ask questions, seek clarity, and work to preserve charitable status, and have written a follow up letter to the Ministers to this end.

If you have questions or concerns, you’re always welcome to reach out to us, or you could write to your own MP. Our friends at the Evangelical Fellowship of Canada have a sample letter, and members can read our November 24 letter in the Knowledge Base if you want to see how we’ve expressed our concern. Our most recent letter will be posted in the Knowledge Base soon!

Noteworthy is provided for general information purposes and does not constitute legal or professional advice. Every organization’s circumstances are unique. Before acting on the basis of information contained in this blog, readers should consult with a qualified lawyer for advice specific to their situation.

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