Leave a commentThe Canada Revenue Agency (CRA) will revoke the registration of Trinity Global Support Foundation, a London-based charity. The notice of revocation will be published in the Canada Gazette with an effective date of May 4, 2013.
On February 1, 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 Trinity Global Support Foundation as a charity. The letter stated, in part, that:
Our audit revealed that the Organization devoted a significant portion of its resources to the promotion of the Mission Life Financial Inc. and Canadians Care donation arrangements. As a result of its participation in these arrangements, between June 1, 2007 and May 31, 2010, the Organization reportedly received nearly $25 million in cash and in-kind property.
With respect to the Mission Life Financial Inc., a registered tax shelter, the Organization issued tax receipts exceeding $1.13 million for cash contributions and $16 million for pharmaceuticals. Of the cash contributions received, the Organization paid nearly $1.03 million to the promoters of the tax shelter and to the Organization’s directors or related parties. It is our position the Organization issued the tax receipts improperly, particularly given our finding that the $16 million recorded for the pharmaceuticals were grossly inflated. As a result, we conclude neither contribution qualifies as gifts at law.
With respect to the Canadians Care promoted donation arrangement, the Organization issued tax receipts exceeding $7.8 million for leveraged cash contributions. The Organization invested over $7 million into investments held by corporations related to its directors and also related to the donation arrangement. These funds were subsequently lost due to the actions of those corporations. The Organization was also found to have improperly paid over $865,000 to individuals and corporations related to the Organization’s directors.