[Recorded by Electronic Apparatus]
Tuesday, June 18, 1996
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[Translation]
The Chair: I call the meeting to order.
[English]
We have with us today Mr. Denis Lefebvre, assistant deputy minister at the policy and legislation branch; Mr. Carl Juneau, assistant director at the technological interpretations and communications charities division; and Ms Lucy Brickman, tax policy officer.
We're here today to talk about Bill C-262, an act to require charitable and non-profit organizations that receive public funds to declare the remuneration of their directors and senior officers.
It's my understanding that you've appeared before us at least three or four times, so welcome once again. I understand that you have some comments to make and then we'll open the floor to questions. Thank you for coming.
Mr. Denis Lefebvre (Assistant Deputy Minister, Policy and Legislation Branch, Revenue Canada): Mrs. Chairman, I am pleased to be here on this important issue, together with my colleagues from revenue and finance.
The issue you are looking at this morning has a fairly long history. If the members will indulge me, I think it would be useful to go through that history to see where we're at now. I think it would be useful as a context for the current decisions the committee has to make.
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The new Bill C-262 was given first reading in the House and is a private member's bill introduced by Mr. Bryden, the hon. member for Hamilton - Wentworth. It was printed pursuant to an order made on March 4, 1996, in the same form as Bill C-224, which was introduced byMr. Bryden on March 15, 1994.
The bill was deemed to have second reading and was referred to the Standing Committee on Government Operations. I think it is important to mention that, because the earlier appearances that I've made here, as you mentioned, were in respect of Bill C-224, which is basically now Bill C-262.
In essence, Bill C-262, like Bill C-224 before it, provides that every charitable and non-profit organization that receives, directly or indirectly, any payment from the public funds of Canada must file with the Minister of Revenue a public information declaration showing the total salaries and benefits received from the organization by each of the directors and senior officers of the organization. By law, the Minister of National Revenue would table in Parliament the name of each organization that has not disclosed the remuneration of the directors and senior officers.
The bill also provided that an organization that failed to comply with the disclosure provisions is guilty of an offence and is liable to a fine in an amount not exceeding 50% of the total amount of public funds received during the year.
As we have mentioned before, we see many problems with the administration of Bill C-262 as presently written. One problem is that the bill would be unenforceable, in that there are a great many obstacles in determining exactly what organizations must comply with these provisions. To require organizations that receive indirect payments to report would cause major difficulties. Organizations would have the task of tracking the original sources of their funds in order to determine their obligation to file.
Even if we were to limit the obligation to report to those organizations that have received direct payments, it would be difficult to identify these organizations without imposing a sizeable burden.
There is no list currently available that would identify these organizations. The preparation of such a list will require very intensive work and will impose a substantial cost to the government and to the organizations. The cost to Revenue Canada to administer the bill would be in the order of$5 million to $6 million for the first five years.
The public disclosure of the remuneration and benefits of senior officials and directors of charitable and non-profit organizations that receive federal funding would be... Here in my written text, I've said ``in contravention to the Privacy Act and section 241 of the Income Tax Act'', but in fact the bill would amend the requirements of those two statutes, so it can be done, but it would be a departure from what is there already.
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The bill provides that failure to comply with the disclosure provisions are punishable on summary conviction by a fine in an amount not to exceed 50% of the total of the federal funds received. Creating an offence for failure to report is contrary to current policy to decriminalize as much as possible failures to meet regulatory requirements. Prosecutions of this type of offence would impose an additional burden and cost on the justice system. An after-the-fact fine would be difficult or impossible to collect from organizations that have few assets and that are dependent in many instances on governments and the public for donations for their funding.
There would be a substantial cost to each of the funding departments in the identification of the recipient organizations and the provision of this information to Revenue Canada. There would be an additional burden and cost to charitable and non-profit organizations that must comply in the preparation and reporting to the department. This would be in addition to the reporting they are currently required to do for tax purposes.
From these comments you can see we see some serious difficulties and disadvantages with the bill as now written. But we have been apprised by the chair of a letter that was written by Mr. Bryden, together with some amendments he has suggested could change the bill in its present form.
For the assistance of the committee I will comment, if you wish, at this time or later - but I can go on and comment at this time - on Mr. Bryden's suggested amendments. I will just mention en passent that in the letter from Mr. Bryden there was a reference to reducing the reporting requirements to apply only to those organizations which receive public funding in excess of $50,000. That was in the letter. But in the amendments it was not there. If the amendments were to go through, there would no longer be any connection with public funding. It's no longer a factor. So the comments I will make are on that basis.
In essence, the requirements of the bill as amended by Mr. Bryden's amendment would be a requirement for both charities and NPOs to report the salaries of the senior executive officers to the nearest $5,000. Then there would be different penalties, which I will go through, depending on whether it's a charity or an NPO.
Basically, the amendments Mr. Bryden has proposed replace the requirement to divulge actual salaries with a requirement to report the range of salaries, in $5,000 increments. Second, it would introduce a rule to eliminate the reporting of any salary under $30,000. Third, it would eliminate the requirement for Revenue Canada to table a non-compliance report in Parliament. Fourth, it would replace the 50% fine for non-compliance by a charity with mandatory revocation of the charity's registered status. Fifth, it would replace the 50% fine for non-compliance by a non-profit organization with the mandatory loss of the organization's tax-free status.
In order to comment on Mr. Bryden's amendments, I have to talk about the earlier discussions that took place at this committee over about the last eighteen months.
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At a meeting of this committee on June 6, 1995, I was asked by committee members when they were discussing Bill C-224, which was the precursor and basically identical to Bill C-262, what could be done administratively or through regulations, without legislation, to collect and make public information on the salaries and benefits of senior officers and directors of registered charities and non-profit organizations. I indicated that consideration could be given to amending the current Revenue Canada public information reporting requirements for all charities to include more specific information on the remuneration of senior officers and directors.
At that time the committee passed a resolution. The resolution read as follows:
- Since the department of Revenue Canada appears to be able to reach the objectives contained in
Bill C-224, namely:
amending the information return (T3010) under the Income Tax Act to ask charitable organizations for more detailed information,
compiling additional information with respect to non-profit organizations.
- Be it moved that consideration of Bill C-224 be set aside until the department of Revenue
Canada provide further information to this Committee...no later than September 30, 1995.
As a response to that motion, we have taken the following actions, which we reported to the committee last fall. Basically, during the discussions of the committee, including witnesses from non-profit organizations, the voluntary sector, and charities, a number of problems had been identified with the public information return for charities. There was a problem of definition. Charities were often not clear as to who was an officer or a director of a charity. We have taken some steps to clarify that in the new return.
We have also amended the return so that charities have to divulge the salaries and benefits of the five highest paid officers, within a range of $20,000. Another problem that had been identified was that some people were leaving those lines blank, and we didn't know whether they didn't pay any officer any salary or whether they had neglected to give us the information. So now we remind every charity of their obligation to file a completed return when it sends out the blank form for the annual return.
Also, we are developing a better computer system so that we can monitor the returns much more closely to ensure that all the lines that have to be filled in are filled in. If they are not, we take action to contact the charity to get the information.
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Before we implemented those changes, we contacted the 15 or so organizations that had appeared before this committee in 1995. More precise information on the returns of directors and officers was being asked for. We wanted to know their views. We also contacted some 50 smaller charities by telephone that had not been represented here at this committee. Basically, they were supportive. They didn't have any problem with giving the additional information that was requested, which I just mentioned.
So given Mr. Bryden's proposed amendments in this committee to Bill C-262 and given the changes we've already made to the reporting requirements for charities, if we look just at the charities, excluding the not-for-profit organizations, from a charity's viewpoint, the only difference left in Bill C-262 as it would be amended along the lines proposed by Mr. Bryden and the current situation, is the ranges of salaries. In our new return, we're asking about salaries within the range of $20,000; in the amendments proposed, salaries would be reported within the range of $5,000.
On the question of the reporting of salary ranges, the privacy commissioner, Mr. Bruce Phillips, advised the committee in his testimony on June 1, 1995, of his concerns with the disclosure of precise information about the amount of salaries paid to various officials. We question whether the slightly better information that could be obtained by moving to reporting ranges of $5,000 is necessary in light of the effect it would have on the rights of individuals to keep their specific information about their remuneration private. In the end, of course, that is for this committee to decide.
On the question of providing for the mandatory revocation of a charity's registered status for failing to divulge the salaries of its officers and directors, I would point out that the only difference between this proposal and the present rules in the Income Tax Act concerning non-compliance by charities is the fact that the minister has some discretion in the matter.
Right now, there are many charities out there run by volunteers. When they fail, for instance, to file the annual information return on time, we don't revoke them automatically. It may be, on their part, simply due to the fact that the volunteers may have changed or they are otherwise busy. So we have a procedure whereby we write to them and call them. We'll probably call them twice each. If we have no response, then we will revoke charity status for failing to file the annual information return.
Now we have stepped up our enforcement and monitoring program in the sense that we are watching closely not only the fact that they didn't send a return, but we want also to take some action when they don't complete or fill some parts of the return that we think should be filled. Annually, we now revoke more than 1,000. It varies, but we revoke more than 1,000 charities for the reason that they have not filed their information return.
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Because of the nature of the charitable sector, we think it is important for the minister to retain some discretion when it comes to revoking charities. Although we think there should be some enforcement and discipline, we do not believe the requirement of the act that a charity be revoked for not filing a certain line on their return should be necessarily statutorily imposed.
Furthermore, it would be a bit of an anomaly to have a statutory requirement to revoke the status of a charity for failing to file one line about the remuneration of directors and not have the same statutory requirement to revoke for failing to file any other line on the return about their activities, the funding they received, the amounts they paid for fund-raising and all kinds of other information that to us are as important as having the salary and benefits of directors and officers.
In conclusion, I note that in response to the steps related to registered charities that I described at the December 12, 1995, meeting of this committee, Mr. Bryden indicated at that time that he was particularly delighted. He also stated that Revenue officials had gone a step further than Bill C-224 in that the top five senior paid officers of a charity are required to disclose their salaries.
I would submit to the committee that the objectives of Bill C-262, as it would be amended by Mr. Bryden, have been met administratively by Revenue Canada as far as registered charities are concerned and there is no need for further legislation in this respect.
I would also submit that a statute separate from the Income Tax Act, containing a number of legal requirements and obligations on the part of charities, would create confusion without adding much to the information we receive.
Now I will turn to the non-profit organizations.
Charities have two tax advantages. One is they are not taxed; they are exempt from tax. Secondly, a very sizeable advantage, of course, is the fact that they can issue tax receipts and the donors can deduct those amounts from their income or receive a credit. A not-for-profit organization has only one tax advantage: it is tax exempt. It cannot issue receipts. So from a tax administration point of view, there is a substantial difference.
Also, because the credibility of charities, as a sector and individually, depends very much on the information donors can obtain, there is a public information return. Very often charities will not have members who can look at the management of the organization in the same way that a not-for-profit organization will have, so there is a public information return.
The main reason for that public information return is so the community and eventual donors or actual donors have more information on charities than they have about not-for-profit organizations, for instance. So the requirement of charities to be more open has been there for a very long time.
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In order to ask for more information about the remuneration paid by non-profit organizations to their directors and senior officials and to make this information public, a cogent argument should be made. We would have to demonstrate that this information is needed in order to administer the system and to ensure that tax obligations are being met or that additional information would assist in tax policy analysis or would otherwise be in the public interest. During the summer of 1995 we worked with the Department of Finance to see if these arguments could be made.
In 1993 the Income Tax Act was amended. Until 1993 not-for-profit organizations did not have any relationship with the tax department. In 1993 the Income Tax Act was amended to require non-profit organizations - not the very small ones, but those that receive investment income of $10,000 or more or that have assets of over $200,000 - to file with Revenue Canada an annual information return.
This return serves two functions. First, it provides a basis for Revenue Canada to monitor the activities of this sector, ensuring that they are indeed maintaining a non-profit status. Second, it provides a profile of the economic activity of the sector, which is useful for tax policy analysis by the Department of Finance.
At present in their return non-profit organizations have to provide all kinds of information on their assets, their activities, and their investment income, but they don't have to provide information about their salaries or benefits of directors and officers. While that information could be useful, it is difficult to see how information related to remuneration of each of the top individuals would serve any tax policy or tax administration purposes.
If a non-profit organization chooses to remunerate its officials at a certain level, that remuneration is taxed in the hands of the recipients. The appropriateness of the remuneration in relation to the duties is not regulated by the tax system.
In addition, as the information collection from non-profit organizations has been in place for only two years, it would be preferable to let the information collection mature before the reporting requirements are changed.
The second aspect regarding information collected from non-profit organizations that Revenue Canada and the Department of Finance considered was should we collect that information only for our own tax purposes or, in addition, should it be made public? Although non-profit organizations enjoy a non-taxable status, they, unlike charities, are unable to issue tax receipts. In the case of charities, disclosure is warranted on the grounds that it is of use to the donating public in making choices.
An argument could also be made that information on the remuneration of senior officials should not be more public than that pertaining to senior officers of commercial corporations that in any one year may not be paying taxes because of losses or for other reasons.
In addition, disclosure of salaries of officers and directors of non-profit organizations, in the absence of some framework within which to evaluate the duties and the appropriateness of the level of remuneration, would not be entirely useful.
For these reasons, Revenue Canada and the Department of Finance would not normally seek to gain the means to make public any information reported by non-profit organizations.
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It is our view that administratively we cannot do what is proposed in Bill C-262 for not-for-profit organizations. We cannot make the information of directors and officers public without an amendment to the legislation. Certainly from a tax policy or a tax administration point of view, we have no need for the collection of such information.
Thank you very much for your attention.
The Chair: On behalf of all members on this committee, I think I'm on safe ground when I thank you for a very comprehensive brief and overview. Also, I would like to commend your officials for responding so swiftly and thoroughly to address some of the concerns raised by Bill C-262 through administrative or regulatory changes.
In keeping with the tradition of this committee and the tradition of courtesy, Monsieur Crête has asked that Mr. Bryden, who has worked so diligently on this issue for a number of years now, lead with the questions.
Mr. Bryden, you have the floor.
Mr. Bryden (Hamilton - Wentworth): Thank you, Madame Chairman.
First, as the author of Bill C-262, I express my thanks to Revenue Canada for the deep consideration they have given the issues it has raised, and the fact that action has been taken.
One of the reasons for wanting to see Revenue Canada officials return to this committee is basically to wind up a process that has taken two years and in my mind is only one stage of a much larger issue. Certainly I think very important progress has been made, and I was very interested in the replies that were made to the amendments. This was one issue that was dropped off the table last year. The amendments were never tabled here, and I heard your comments on those amendments with great attention.
I would like to ask some questions, if I may, on general issues, because as I say, this is to me a much larger issue that goes beyond the remuneration of executive officers. It's an issue that pertains to the whole accountability of the not-for-profit sector.
In your concluding remarks in commenting on non-profit organizations and the type of disclosure that's involved there, I notice you say there's neither tax policy nor tax administration rationale for collecting the required information. That raises with me the issue of how does one approach what I see as a need for reform in the not-for-profit sector, which has to do not just with tax issues but with ethical issues, with whatever responsibility government has in providing an oversight role to the management of a sector of the economy that is, of course, multi-billion dollar? We're looking at over $80 billion in charities alone.
So I would like to ask you, does Revenue Canada have any role in your mind in looking at or providing some sort of ethical standard charities should abide by?
Mr. Lefebvre: I think we have to make a distinction between charities and NPOs. In the case of charities, in terms of ethical questions, management questions that you raised, I would think the community that charities serve is one group. Most times they have a board of directors from within the communities so there are some means within a community, and it depends on the size. Sometimes it's a bit diffused and difficult to get this to work, but I think the community is one means of monitoring and keeping an eye on the activities of a charity.
Certainly donors also exert some discipline on charities. They can ask questions. There is a public information return, and charities live off donations, for the most part. If they don't maintain their credibility, as a sector and individually, they just lose this ability to raise funds. So I think donors exert some discipline or pressures on charities to behave, to have proper management and ethical conduct.
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It is also important to note that charities as organizations, and the law of charity and the management of charities as trusts, if you wish, of the people, come under provincial jurisdiction. So improper conduct can be investigated by provincial authorities.
I recognize provincial authorities are unequal in the attention they pay to that sector. We always talk about the public trustee of Ontario, which is perhaps more active than the supervisory body in other provinces.
On the other hand, we recognize that popular belief is that Revenue Canada is the only agency monitoring the activities of charities. It puts on us a pressure that may or may not be totally warranted, but it is a fact of life.
That's why the information return we get from charities is public to a very large extent. It's almost a public service. For pure tax purposes we could just take those returns and keep them confidential and go and audit charities. But because there is so much expectation on the revenue department to monitor the behaviour of charities, we try to go one step further and assist in the monitoring of charities.
But to expect the revenue department... And here, as Mr. Bryden has mentioned in the past, if not now, the bill talks about public funding. A very vast number of charities receive funds from public bodies on all levels of government, and various levels of strings are attached to the funding they receive. Sometimes it's outright grants and very few controls. But charities also have to maintain their credibility vis-à-vis their funding governments, whether they are municipal, provincial, or federal, and a number of contractual and reporting requirements are imposed on charities, and for that matter on not-for-profit organizations. So a number of organizations and layers have a responsibility for, or oversee, the activities of charities.
We are not in the business of controlling the management of charities. If we are informed, or if through an audit we become aware, that the remuneration is excessive, we will take action to revoke a charity. If the remuneration is excessive, above normal market value, or if there are other abuses, we can and will revoke a registration, because then we can say the funds are not spent on charitable purposes and charitable activities. But that is not to say we go in there and do some management evaluations. We are just not in that business. It has to come from the other controls I've just mentioned.
For NPOs there are no donors. Very often, though, they receive some direct funding. Inasmuch as they receive some direct funding, our view is that it is again the level of government, whether it's a municipal, provincial, or federal government, that is providing some direct funding, whether for research or whatever the purpose is.
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If we want to improve the management and the accountability of NPOs receiving public funding, it seems to me that one way would be for those that are responsible for the public funding, for specific purposes presumably, to control those expenses and ensure that the money they give to the NPOs is well spent. In addition, a lot of NPOs have members who pay membership fees. They have annual meetings and elect directors and that sort of thing. I think that by and large the management of those organizations is assisted by the interest members have in good and proper management of the NPOs. It affects the services members receive and the level of their membership. So I think there are a number of ways in which NPOs and charities are already being monitored.
Over the last three years our department has done some 2,000 audits of charities. We have to conclude based on those audits that there is no widespread abuse in the sector. Mr. Bryden has on occasion mentioned that there were some abuses, and I am the last one to say there are none. On the other hand, it's not widespread. We have no evidence whatsoever to indicate widespread abuse in the sector, although we recognize that there is an occasional unfortunate event that affects the credibility of the whole sector.
I've been a bit long-winded, Mr. Bryden. Sorry about that. Maybe it was a beautiful question.
Mr. Bryden: I'll run out of time, but that's fine.
Following up, won't you agree that whether it's charity directors or donors or whoever, and this applies to non-profits as well, the quality of scrutiny or the management and control they have over the organizations is dependent on the quality of information they have? The role of the T3010 form can be precisely that, to provide good information to potential donors and to the directors, because the directors cannot always rely on the paid management of the charity or non-profit organization to tell them candidly the financial details. Something like this, however, does have a very important role, is that no so?
Mr. Lefebvre: I agree totally.
Mr. Bryden: Then in that context, aren't I right to be concerned about the quality of information that has been occurring on the T3010 form over the years? What prompted the start of Bill C-224 was the fact that the remuneration lines were consistently blank in so many charity forms. You yourself said there were ambiguities in the information, in the questions asked. Similarly there may still be problems with the rest of the form. Isn't it a fair target to want to ensure that the data demanded on forms like this are of very high quality and that Revenue Canada, subject to its resources, would monitor as expertly as it can?
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Mr. Lefebvre: I agree. In fact, the mere introduction of Bill C-224 and the discussions we had in the past caused us to take a very hard look at that situation. We have found the reporting to be less than 100%, and we have taken a number of steps to improve the reporting of the precise information covered by Bill C-224. While we were at it, we have in fact strengthened our monitoring of the reporting that goes beyond remuneration. Now, as I mentioned, we want to give equal weight to all the information.
First of all, if we ask for the information it is because we believe that information is needed by us and by the donors. So now whenever we ask for any information we will ask that people don't leave lines blank. If they don't put down any remuneration, they will say ``we don't pay people''; otherwise we don't know whether there is no remuneration or whether they have just decided not to give the information that year.
We will monitor that. I am sure that the stepped-up monitoring of the return will make for more revocation on the one hand, but more importantly for better information for all those who want to know what charities are all about and what they're doing.
Mr. Bryden: Thank you.
The Chair: We have a certain amount of latitude; perhaps Mr. Gilmour can have a turn, and then if you have other questions...
Mr. Gilmour.
Mr. Gilmour (Comox - Alberni): I'll be brief, because I'd like to hear John's point of view; he's obviously more up to speed than the rest of us.
I share Mr. Bryden's views on accountability. To my mind, with any group that is handling funds that doesn't have a watchdog or a monitoring function, there is a perception that they are free to do as they wish, whereas if there is a monitoring function there they know that the possibility of someone coming to either audit their funds or have a look at them is there. I think it's a deterrent that should be there.
I've got a good example - not mentioning names - in my riding on Vancouver Island of a group that clearly was off the rails, an NPO that was getting government grants as well as memberships, and if it were a private firm it would have bordered on fraud. There needs to be some way for these people to basically jerk their chain and have them report and account.
That was kind of a preamble. As a question, what percentage of the non-profit organizations, if you take out the bottom line of people who are exempt, are we talking about? Would it be half that would be forced to report, or a quarter? Of course there's the bottom limit where people don't report, but what's the scale?
Mr. Lefebvre: Frankly, I don't think we have any reliable figures. The only thing - again, it's embryonic - we've started... The law was passed in 1993, so the first year of reporting was probably 1994-95 and we received 5,000 returns. That's again with a cut-off of $10,000 of investment income or $200,000 in assets. NPOs are throughout all communities, little leagues for example, and it's difficult to have a reliable count of NPOs in Canada.
Mr. Gilmour: Okay.
An hon. member: John, have another shot at it.
Mr. Bryden: Only if there's no one else...
The Chair: Mr. Harvard.
Mr. Harvard (Winnipeg St. James): I had some observations, which I will make, and then if John wants to speak further it's certainly okay with me.
First of all, I think all of us are concerned about accountability. Any time you have public funds at stake, public funds being spent, we want to have a pretty good idea of how the funds are being expended, so that we can feel they are being spent properly.
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I do think that at the same time we have to be somewhat careful of how far we go. I would invoke the old cliché about big brother. As a government, we can become too nosy, too snoopy, too oppressive, and we have to remind ourselves about whom we're dealing with. We're dealing with charities and non-profit organizations. As far as I know, most of them are reputable. We're talking about the Salvation Army and others like that.
I think we have to ask ourselves whether we have reached a reasonable balance so that the interests of the charities and the NPOs are protected, as well as the interests of the taxpayer, the general public. I am one who believes we are at a reasonable balance.
I think it is noteworthy that the charities have been quite supportive of the amendments introduced by Revenue Canada. I think that shows that they are sensitive to these issues and that they want to be as responsible as possible without having to reveal absolutely everything they do and say.
We have come quite a distance on this issue since the introduction of Bill C-224. I think both Revenue Canada and Mr. Bryden are deserving of praise from this committee. Revenue Canada has taken these concerns seriously and obviously has taken some steps where possible, mostly or all on the charity side, because when it comes to the NPOs, if there were going to be amendments and adjustments, that really is not within your purview, as I understand it. That comes under the Income Tax Act and the Privacy Act, and that's really beyond your jurisdiction.
So I think this committee can take some pride in having made some progress, but of course I think it's Mr. Bryden who deserves most of that praise because he raised the issue. I would hope that at this juncture we would be able to say, in effect, we've come some distance, we've done the job, and there's really no need for the bill to proceed any further.
I think the House of Commons should be made aware of what we have done, especially of what you have done, as a department of the government. I would be in favour of some kind of report. It would be my feeling that we should not proceed any further because the job has been done.
That's all I would say at this point, but I think John wants to say something else.
Mr. Bryden: I thank you for your remarks as well, and I would echo them to a large degree. I still think much has yet to be done. There are large issues here in the not-for-profit sector that I'll continue to examine, but I do think that Bill C-224 or C-262, whatever you would like to call it, has had an effect that is as far as any private member could hope for from a piece of legislation he puts forward.
It has obviously had an impact on setting an agenda for change. That's very much due to the cooperation that has come from Revenue Canada and its receptiveness, because a private member's bill by its very nature is very inexact and incomplete. It's like firing an arrow into the air and hoping it hits a target somewhere.
We appear to have hit a target here of some kind, and I think I will take Mr. Harvard's suggestion up. I would be personally delighted if this committee would send some sort of message to the House of Commons that Bill C-262 has been dealt with in a very appropriate manner. It has accomplished some important things and it has probably gone about as far as it can go. I think what we're looking at now is another stage, in which we have to look at the broader issues you've touched on today.
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All I can say further to that is that I thank you very much. It has been about eighteen months. It's now time to leave Bill C-262 behind us. But I have to tell you you haven't heard the last of me.
The Chair: It was sounding rather positive until that ominous note was injected.
Are there any other comments or questions?
Mr. Malhi (Bramalea - Gore - Malton): Yes, I have a question. I understand some of the non-profit organizations are required to file an annual information return while others are not. Could you explain why there is a difference?
Mr. Lefebvre: I guess it was a matter of not imposing. As I mentioned, not-for-profit organizations are found throughout Canadian communities. It's any association - again, I mention little leagues - that grows to assist communities across Canada. From a tax point of view, we asked for an information return and we decided to have it cut off, so the very small organizations would not have this burden of reporting to government when we didn't see a real purpose. We didn't think a not-for-profit organization with less than $10,000 in annual investment revenue or $200,000 in assets would be of interest from a tax point of view. Purely not to add a paper burden on Canadians when it does not serve...
It's easy to say all not-for-profits have to report with penalties and what not. But for reasons that have been mentioned here today, we try to be circumspect when we ask for further reporting before we add to the paper burden of Canadians. So that was a judgment call that seemed like an amount that was reasonable.
The Chair: On that happy note, I think we've witnessed an exemplary performance of how officials from Revenue Canada were so capable and were able to oblige members of this committee. Thank you for working with us.
On that happy note, we'll adjourn. Thank you.
Mr. Lefebvre: I know we've adjourned, but if we can be of assistance if you intend to report to the House, we'll be delighted.
The Chair: I'm informed there's no real mechanism to table anything in the House on a private member's bill. But thank you for the offer of assistance. I'm sure we'll have ample reason to call on you again.
The meeting is adjourned.