Kim, it seems like an expansion should address the current de minimis rules. Perhaps the $10,000 revenue test should be expanded beyond dividends, interest, rents and royalties to include revenues received from non-members, or all revenues if the organization has more than some realistic number of members to avoid a 20,000 member "NPO" health club. Maybe set that revenue test at $30,000, the small supplier threshold for GST/HST.
It's mind-boggling that "every NPO, no exceptions" could even make it into the economic statement, much less draft legislation. Apparently no lessons have been learned from UHT and bare trusts.
Original Message:
Sent: 09-19-2025 10:11
From: Kim Moody
Subject: Proposals for NPO Disclosures
I don't disagree with the sentiments that the proposed disclosure rules might sweep in small clubs and "knitting circles" but the push for more disclosure is certainly something I agree with. I've come across many organizations over the years that classify themselves as non-profits, compete head-on with for-profit businesses and pay no tax. Fitness clubs and other sporting organizations fit into that category that I've seen. And, at a minimum, the CRA should have more visibility for organizations like that to review whether or not the NPO tax exemption is appropriate or not. Hopefully the proposed legislation will be modified to appropriately target better.
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Kim G C Moody FCPA, TEP
Founder, Moodys Tax / In the Mood Content Creator
Original Message:
Sent: 09-18-2025 15:01
From: John Oakey
Subject: Proposals for NPO Disclosures
As you can see from the Department of Finance explanatory notes, there is no de minis test or special criteria that needs to be met. If you are a not-for-profit organization that does not file a T1044, then you are required to file an information return to CRA:
Finance Explanatory notes
proposed new subsection149(13)
New subsection 149(13) requires any organization exempt from tax under paragraph 149(1)(e) or (l) to file an information return (unless the organization is otherwise required to file a return under subsection 149(12) for the same period). This short-form information return must contain prescribed information including a description of the organization's activities (including whether it conducts activities outside Canada), the organization's total assets, total liabilities and total amounts received for the period, and the name and address of each director, officer or trustee of the organization.
This amendment applies to fiscal periods that begin on or after January 1, 2026.
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John Oakey
CPA Canada
Original Message:
Sent: 09-18-2025 13:19
From: Hugh Neilson
Subject: Proposals for NPO Disclosures
Thanks to Allan Lanthier for his Globe and Mail article on the vast overreach of these proposals. I'm not sure if the article at https://www.theglobeandmail.com/business/commentary/article-canada-revenue-agency-cra-tax-finances-lanthier/ is paywalled, but I suspect he would not mind me quoting the sample list of entities that would have disclosure requirements.
"For example, private golf clubs are NPOs and tax-exempt. So too, says the CRA, are groups such as bridge clubs, bingo halls, knitting groups, sports organizations (an old-timers' hockey league would be one example) and festivals such as a Santa Claus parade." After school clubs missed his list. Arguably, a regularly scheduled family dinner or a family reunion - or millions of other organized or semi-organized activities - will be subject to these proposed requirements.
"Oh, that will NEVER actually happen!" That's what I heard about the bare trust requirements too. Not the UHT requirements - they were already happening before we figured out they were in progress.
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Hugh Neilson
Kingston Ross Pasnak LLP
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