CBC recently reported in an article "Giving Tree Foundation to be stripped of charity status: Charity that gives $2M a year to children's causes faces demise after tax review". CBC notes "The group has a relationship with EquiGenesis Corp., a company that designed a complicated donation tax strategy that helped the Giving Tree Foundation quickly raise millions of dollars after it was re-organized five years ago."
Here is the CBC article: http://www.cbc.ca/news/politics/giving-tree-foundation-to-be-stripped-of-charity-status-1.3074967
Here is the CharityFocus profile on Giving Tree Foundation: http://www.charityfocus.ca/EN/Pages/CharitySummary.aspx?charityid=842385874RR0001&enddate=2013-06-30
Here is a press release from the charity: Children's charitable foundation concerned by CRA's aggressive tactics
It will be interesting to see one day the CRA letters to the charity. Another unfortunate piece of the coverage is the second last sentence "The Canada Revenue Agency has come under fire in recent years for is a political-activity audits of Canadian charities, a $13.4-million program that launched in 2012 and has involved about 60 charities." It appears to be totally irrelevant to the issues in this case but if you read the comments most of the people assume that this is a political activity related audit!
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Mark Blumberg is a partner at the law firm of Blumberg Segal LLP in Toronto and works almost exclusively in the areas of non-profit and charity law.