Ottawa, Ontario, March 15, 2013... The Canada Revenue Agency (CRA)
will revoke the registration of Marketplace Ministries International, a
Scarborough-based charity. The notice of revocation will be published in
the
Canada Gazette with an effective date of March 16, 2013.
On January 31, 2013, and in accordance with subsection 168(1) of the
Income Tax Act,
the CRA issued a notice of intention to revoke the registration of
Marketplace Ministries International as a charity. The letter stated, in
part, that:
“Our audit revealed that the Organization has devoted a significant
portion of its resources to the promotion of the Insured Giving Donation
Program tax shelter gifting arrangement. Our audit has concluded that
from January 1, 2009 to December 31, 2010, the Organization issued in
excess of $23 million in receipts for cash and non-cash gifts received
through this tax shelter arrangement. Of this amount, $19 million
consisted of non-cash gifts that the Organization reports to have
distributed as part of its own activities. However, the Organization’s
records fail to substantiate that the property actually existed, that
the property was in the Organization’s possession, that the values
recorded on the receipts were accurate or that the property was
distributed for charitable purposes.
The remaining $3.9 million was reported as tax-receipted cash
donations. Of this amount, the Organization directed $3.8 million to
fundraising expenses and retained only $125,370 over the two years for
use in its own charitable activities. The Organization’s earnings
represent 3% of the gross cash donations received or 0.5% of the gross
tax-receipted donations reported.
It is our position that the Organization has operated for the
non-charitable purpose of promoting a tax shelter arrangement and for
the private benefit of the tax shelter promoters. The Organization has
issued receipts for: transactions that do not qualify as gifts; issued
receipts otherwise than in accordance with the
Income Tax Act and its Regulations; failed to maintain sufficient books and records; and failed to file an accurate T3010,
Registered Charity Information Return.”
A copy of the notice of intention to revoke and other letters
relating to the grounds for revocation are available to the public on
request, in the language they were originally written, by calling
1‑800‑267‑2384.
An organization that has had its registration as a charity revoked
can no longer issue donation receipts for income tax purposes and is no
longer a qualified donee under the
Income Tax Act. The
organization is no longer exempt from income tax, unless it qualifies as
a non-profit organization, and it may be subject to a tax equal to the
full value of its remaining assets.
Registered charities perform valuable work in our communities, and
Canadians support this work in many ways. The CRA regulates these
organizations through the
Income Tax Act and is committed to
ensuring that they operate in compliance with the law. When a registered
charity is found not to comply with its legal obligations, the CRA may
revoke its registration under the
Income Tax Act.
The CRA is reviewing all gifting tax shelter schemes (for example,
schemes that typically promise donors a tax receipt worth more than the
actual amount of the donation), and it plans to audit every
participating charity, promoter, and investor. For more information
about tax shelters, go to the CRA’s Tax Alert Web page at
www.cra.gc.ca/alert.
For more information about the registration of Canadian charities, go to the CRA’s Charities and Giving Web page at
www.cra.gc.ca/charities.
Canada Revenue Agency
This a a reproduction copy of an official work that is published by the Government of Canada and that the reproduction has not been produced in affiliation with, or with the endorsement of the Government of Canada.