Here is a CRA document we recently received through the ATIP system Posting New Content on the CRA's Charities and Giving web pages. If you are wondering how difficult it is for the Charities Directorate to even post the simplest information this chart will help. The short answer - it is difficult. While bloggers can put up information in minutes the CRA system can take months, years and even decades to get a document published online. I am still waiting for CRA to release their guidance on religion, the first consultation draft was done about 9 years ago!
By the way, this is a real chart - it is not some poor comedic attempt by myself and a couple of geeks to pretend we have a sense of humour. On a serious note, this level of rigidity makes it very hard for CRA to publish many documents that are quite important for charities and others to have to understand the CRA's positions on important issues, and have rule of law in Canada as it relates to charities. Not sure what can be done about that - but we try to help in our small way by publishing online some of the material that CRA has produced, that is obtained through ATIP, but CRA is not allowed to place on their website.
Do you require legal advice with respect to Canadian or Ontario non-profits or charities?
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.