PFC Submission for the Government of Canada 2025 Pre-budget Consultations – March 10, 2025

SUMMARY 

Recommendation 1 – Follow-through on the Government’s commitment for a review of the disbursement quota rate by 2027 and commit to a regular review. 

Recommendation 2 – Incentivise impact investment: issue guidance for charities on making Program Related Investments, and de-risk philanthropic investments with government commitments. 

RECOMMENDATION 3 – Attend to serious lingering challenges of the Qualifying Disbursement Regime by making a technical amendment to the Income Tax Act to ensure charities can pool funds and grant to NQDs, and help interested charities facilitate changes to their charitable purposes so they can grant to NQDs. 

Recommendation 4 – Fix the data deficit: task Statistics Canada to carry out the nonprofit module of the Canadian Survey of Business Conditions every year and establish a permanent unit at Statistics Canada focused on the non-profit and charitable sector. 

Recommendation 5 – Designate the Tax Court of Canada as the primary appeals reviewer of CRA decisions that refuse or revoke registrations of charities. 

Recommendation 6 – Continue and strengthen the critical partnership between the Federal Government and the non-profit and charitable sector.