Christ Apostolic Church of God Mission International v. Canada (National Revenue)

Christ Apostolic Church of God Mission International v. Canada (National Revenue)

The Minister was entitled to revoke the appellant's charitable registration because the compliance agreement was subject to Ministerial review and the Minister could conclude that the appellant's non-compliance was so substantial it could not be remedied by the agreement; moreover, no breach of procedural fairness...

Source-derived case information.

Citation
2009 FCA 162
Parties
Appellant: Christ Apostolic Church of God Mission International; Respondent: The Minister of National Revenue
Court
Federal Court of Appeal
Jurisdiction
Canada
Judgment Date
20 May 2009
Procedural Posture
Appeal Under S.172 Income Tax Act (revocation of Charitable Registration) / Federal Court of Appeal Decision Following Audit, Objection Process and Notice of Intention to Revoke
Outcome
Appeal dismissed with costs
Legal Topics
Revocation of Charitable Status, Compliance Agreement, Natural Justice, Ministerial Discretion, Objection Process
Source Language
en
Income Tax Charities Law Administrative Law Procedural Fairness Revocation of Charitable Status Compliance Agreement Natural Justice Ministerial Discretion +1 more

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Parties

Christ Apostolic Church of God Mission International

Appellant

The Minister of National Revenue

Respondent

Procedural Posture

Appeal Under S.172 Income Tax Act (revocation of Charitable Registration) / Federal Court of Appeal Decision Following Audit, Objection Process and Notice of Intention to Revoke

  1. 1 Whether a compliance agreement signed during audit prevented the Minister from later revoking charitable registration
  2. 2 Whether the compliance agreement was binding and could not be unilaterally set aside by the Minister
  3. 3 Whether the Minister breached natural justice or procedural fairness by revoking registration without first allowing submissions that the compliance agreement was a sufficient sanction

Ratio Decidendi

The Minister was entitled to revoke the appellant's charitable registration because the compliance agreement was subject to Ministerial review and the Minister could conclude that the appellant's non-compliance was so substantial it could not be remedied by the agreement; moreover, no breach of procedural fairness occurred because the appellant had the opportunity to make submissions during the objection process and did not do so.

Court Disposition

Appeal dismissed with costs

Orders

  • Appeal dismissed with costs