CRA recently released a letter which considers whether a Tribal Council should be considered a public body performing a function of government within the meaning of paragraph 149(1)(c).
CRA ruled that the Tribal Council was considered to be a public body performing a function of government in Canada within the meaning of paragraph 149(1)(c) of the Act, and, accordingly, was exempt from tax under Part I of the Act.
Here is a copy of the full CRA letter.
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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.