College rabbinique de Montreal Oir Hachaim D'Tash v. Canada (Minister of the Customs and Revenue Agency)

College rabbinique de Montreal Oir Hachaim D'Tash v. Canada (Minister of the Customs and Revenue Agency)

The Court concluded the Minister did not err: even accepting that the appellant lacked opportunity to respond to some asserted grounds, there were sufficient substantiated grounds (non-gifts for receipts, resources not devoted to charitable purposes, failure to keep required records, loans to non-qualified and...

Source-derived case information.

Citation
2004 FCA 101
Parties
Appellant: Collège Rabbinique de Montréal Oir Hachaim D'Tash; Respondent: The Minister of the Canadian Customs and Revenue Agency
Court
Federal Court of Appeal
Jurisdiction
Canada
Judgment Date
9 March 2004
Procedural Posture
Appeal (revocation of Charitable Registration) / Final Judgment (appeal Heard and Decided)
Outcome
Appeal dismissed with costs.
Legal Topics
Revocation of Charitable Registration, Interpretation of Income Tax Act S.118.1, Procedural Fairness, Record Keeping Requirements S.230(2), Loans to Non Qualified Donees, Non Arm's Length Transactions
Source Language
en
Tax Law Charity Law Administrative Law Revocation of Charitable Registration Interpretation of Income Tax Act S.118.1 Procedural Fairness Record Keeping Requirements S.230(2) Loans to Non Qualified Donees +1 more

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Parties

Collège Rabbinique de Montréal Oir Hachaim D'Tash

Appellant

The Minister of the Canadian Customs and Revenue Agency

Respondent

Procedural Posture

Appeal (revocation of Charitable Registration) / Final Judgment (appeal Heard and Decided)

  1. 1 Whether the Minister erred in revoking the appellant's charitable registration
  2. 2 Whether receipts issued represented "gifts" within s.118.1(1) of the Income Tax Act
  3. 3 Whether the charity's resources were devoted to charitable purposes

Ratio Decidendi

The Court concluded the Minister did not err: even accepting that the appellant lacked opportunity to respond to some asserted grounds, there were sufficient substantiated grounds (non-gifts for receipts, resources not devoted to charitable purposes, failure to keep required records, loans to non-qualified and non-arm's-length donees) that justified revocation of registration, and the appellant had full opportunity to address those principal grounds.

Court Disposition

Appeal dismissed with costs.

Orders

  • Appeal dismissed with costs.